Boyd v. Walmart

Filing 10

STIPULATION and ORDER signed by Magistrate Judge Jeremy D. Peterson on 5/8/24 Regarding Production of Confidential Documents and Proprietary Information. (Kastilahn, A)

Narak Mirzaie, SBN 311508
[e-mail]
2 M LAW ATTORNEYS, APC
680 East Colorado Blvd., Suite 180
3 Pasadena, CA 91101
Telephone: [phone]
4 Facsimile: 626-626-4420
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Attorney for DIANE BOYD

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JAMES T. CONLEY, SBN 224174
[e-mail]
JANE A. ROTHBALER, SBN 201755
[e-mail]
OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
400 Capitol Mall, Suite 2800
Sacramento, CA 95814
Telephone: [phone]
Facsimile: 916-840-3159

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Attorneys for WALMART INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DIANE L. BOYD, an individual;

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Plaintiff,

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Case No. 2:24-cv-00275-DJC-JDP
STIPULATION REGARDING
PRODUCTION OF CONFIDENTIAL
DOCUMENTS AND PROPRIETARY
INFORMATION AND ORDER

vs.

WALMART; A Corporation Doing
Business in California; and DOES 1
20 through 50, inclusive;
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Defendants.

Action Filed:
Trial Date:

December 18, 2023
None Set

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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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IT IS HEREBY STIPULATED by and between Plaintiff BOYD (“Plaintiff”)

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and Defendant WALMART INC. (“Defendant”) (collectively, “the Parties”), through

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their respective attorneys of record, that a Protective Order be entered by this Court as

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follows:

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1.

This Stipulation and Protective Order shall apply to the production and

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exchange of all document requests and documents, interrogatories and answers to

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interrogatories, depositions, request for admissions and responses to requests for

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admissions, exhibits, pleadings, admission of evidence at trial, and all other

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information exchanged and furnished in this action by the Parties that are confidential

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and/or proprietary.
2.

The Parties acknowledge that discovery will require disclosure of

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information that is private, personal, privileged, confidential, proprietary, or

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nonpublic. As a result, the Parties agree that they will be required to enter this

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Stipulation and Protective Order (hereinafter “Order”) on the following terms to

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ensure the continuing confidentiality of materials designated as Confidential Material

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in this litigation. Confidential Material, as used in this Order, shall refer to any

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document or item designated as “Confidential” or “Highly Confidential – Attorneys’

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Eyes Only”. The Parties understand that this Order does not confer blanket protections

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on all disclosures or responses to discovery and that the protection it affords extends

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only to the limited information or items that are entitled under the applicable legal

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principles to treatment as confidential. Nothing in this Order shall require any party to

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produce any specific document or category of documents which a party deems

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inappropriate for production.

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I.

Definitions of Confidential Material

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3.

Confidential Material, as used in this Order, consists of the following

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materials and categories of materials:
(a)

Materials relating to any privileged, confidential, or nonpublic

information, including, but not limited to, trade secrets, research, design,
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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development, financial, technical, marketing, planning, personal, or commercial

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information, as such terms are used in the Federal Rules of Civil Procedure and

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any applicable case law interpreting Federal Rule of Civil Procedure

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26(c)(1)(G), contracts, non-public compilations of retail prices; proprietary

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information, vendor agreements; personnel files; claim/litigation information;

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nonpublic policies and procedures; medical records; employment offers;

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competitive analyses, income statements; client or customer information;

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financial records and statements; vendor agreements, along with other

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proprietary or confidential information.
(b)

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Materials containing corporate trade secrets, nonpublic research

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and development data, including, but not limited to, cost data, pricing formulas,

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inventory management programs, and other sales or business information

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known to the public; information obtained from a non-party pursuant to a non-

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disclosure agreement; and customer-related Protected Data shall be deemed

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“Highly Confidential – Attorneys’ Eyes Only”.
(c)

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“Protected Data” shall refer to any information that a party believes

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in good faith to be subject to federal, state or foreign data protection laws or

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other privacy obligations. Examples of such data protection laws include but are

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not limited to The Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq. (financial

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information); and, The Health Insurance Portability and Accountability Act and

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the regulations thereunder, 45 CFR Part 160 and Subparts A and E of Part 164

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(medical information). Certain Protected Data may compel alternative or

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additional protections beyond those afforded “Highly Confidential – Attorneys’

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Eyes Only” material, in which event the Parties shall meet and confer in good

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faith, and, if unsuccessful, shall move the Court for appropriate relief.

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4.

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The Parties shall not designate as confidential information that is already

public knowledge.
5.

The Parties agree that such Confidential Material as described in
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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paragraph 3 above, should be given the protection of an order of this Court to prevent

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injury through disclosure to persons other than those persons involved in the

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prosecution or defense of this litigation. A Protective Order will serve to achieve the

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following: expedite the flow of information, facilitate the prompt resolution of disputes

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over confidentiality of discovery materials, adequately protect information the Parties

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are entitled to keep confidential, ensure that the Parties are permitted reasonable

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necessary uses of such material in preparation for and in the conduct of trial, and

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address their handling at the end of the litigation.

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II.

Procedure for Designating Information as Confidential

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6.

To designate information as confidential, the producing party shall mark

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Confidential Material with the legend “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. Parties shall submit confidential

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discovery responses, such as answers to interrogatories or answers to requests for

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admissions, in a separate document stamped with the appropriate legend designating

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those responses as Confidential Material. The Receiving Party may make copies of

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Confidential Material and such copies shall become subject to the same protections as

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the Confidential Material from which those copies were made.

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(a)

Information on a disk or other electronic format (e.g., a native format

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production) may be designated confidential by marking the storage medium itself (or

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the native file’s title) with the legend “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. The Receiving Party shall mark

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any hard-copy printouts and the storage medium of any permissible copies of such

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electronic material with the corresponding legend contained on the original and such

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copies shall become subject to the same protections, as the Confidential Material from

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which those copies were made.

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(b)

Information disclosed at any deposition of a party taken in this action may

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be designated by the party as confidential by indicating on the record at the deposition

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that the information is confidential and subject to the provisions of this Order.
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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Alternatively, the party may designate information disclosed at the deposition as

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confidential by notifying the court reporter and other parties in writing, within fifteen

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(15) business days of receipt of the transcript, of the specific pages and lines of the

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transcript which are designated as confidential. The Parties may agree to a reasonable

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extension of the 15-business-day period for designation. Designations of transcripts

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will apply to audio, video, or other recordings of the testimony. During such 15-

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business-day period, the entire transcript shall receive confidential treatment. Upon

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such designation, the court reporter and each party shall affix the “CONFIDENTIAL”

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or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to the

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designated pages and segregate them as appropriate.
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A producing party may change the confidentiality designation of

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materials it has produced, as follows: (1) The producing party must give the receiving

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parties notice of the change by identifying the documents or information at issue. Once

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notice is given, the receiving party must make good-faith efforts to ensure that the

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documents or information are accorded treatment under the new designation. (2)

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Within a reasonable period after giving notice, the producing party must reproduce the

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documents or information in a format that contains the new designation. (3) If such

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information has been disclosed to persons not qualified pursuant to paragraph(s) (14-

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15) below, the party who disclosed such information shall (a) take reasonable efforts

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to retrieve previously disclosed Confidential Material; (b) advise such persons that the

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material is Confidential; and (c) give the producing party written assurance that steps

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(a) and (b) have been completed.

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III.

Data Security

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8.

The Parties agree to provide adequate security to protect data produced

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by the other party(ies) or by non-parties. This includes secure data storage systems,

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established security policies, and security training for employees, contractors and

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experts. Adequate security also includes such measures as data encryption in transit,

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data encryption at rest, data access controls, and physical security, whether
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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hosted/outsourced to a vendor or on premises. At a minimum, any receiving party

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subject to the terms of this Order, will provide reasonable measures to protect non-

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client data consistent with the American Bar Association Standing Committee on

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Ethics and Professional Responsibility, Formal Opinion 477R.

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IV.

Clawback Provisions

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9.

The production of privileged or work-product protected documents,

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electronically stored information (ESI) or information, whether inadvertent or

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otherwise, is not a waiver of the privilege or protection from discovery in this case or

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in any other federal or state proceeding.

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10.

This Order shall be interpreted to provide the maximum protection

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allowed by Federal Rule of Evidence (FRE) 502(d) and shall be enforceable and

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granted full faith and credit in all other state and federal proceedings by 28 U.S. Code

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§ 1738. In the event of any subsequent conflict of law, the law that is most protective

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of privilege and work product shall apply.

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11.

Nothing contained herein is intended to or shall serve to limit a party’s

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right to conduct a review of documents, ESI or information (including metadata) for

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relevance, responsiveness and/or segregation of privileged and/or protected

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information before production.

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12.

If the receiving party has reason to believe that a produced document or

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other information may reasonably be subject to a claim of privilege, then the receiving

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party shall immediately sequester the document or information, cease using the

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document or information and cease using any work product containing the

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information, and shall inform the producing party of the beginning BATES number of

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the document or, if no BATES number is available, shall otherwise inform the

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producing party of the information.

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13.

A producing party must give written notice to any receiving party

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asserting a claim of privilege, work-product protection, or other ground for reclaiming

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documents or information (a “clawback request”). After a clawback request is
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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received, the receiving party shall immediately sequester the document (if not already

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sequestered) and shall not review or use that document, or any work product

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containing information taken from that document, for any purpose. The Parties shall

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meet and confer regarding any clawback request.

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V.

Who May Receive Confidential and Highly Confidential Information

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14.

Confidential Material. Any Confidential Material and the information

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contained therein shall be disclosed only to the Court, its staff, in-house counsel and

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outside counsel of record for each party, and also shall be disclosed on a need-to-know

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basis only to the Parties, counsel’s staff personnel, employees of a party to whom

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disclosure is necessary in connection with the preparation for and trial of this action,

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and any witnesses in the case (including consulting and testifying experts) as may from

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time to time reasonably be necessary in prosecution or defense of this action.

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Highly Confidential—Attorneys’ Eyes Only Material. Material and

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information designated as “Highly Confidential—Attorneys’ Eyes Only” shall only be

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disclosed to the Court, its staff, in-house and outside counsel of record for each party,

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the secretarial, clerical, and paralegal staff of each, and consulting and testifying

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experts retained by a party in this action.

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16.

Restriction on Disclosure to Direct Competitors. Notwithstanding the

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foregoing, Confidential Material shall not be disclosed to any current or former

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employees of, or current or former consultants, advisors, or agents of, a direct

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competitor of any party named in the litigation. If a Receiving Party is in doubt about

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whether a particular entity is a direct competitor of a party named in this lawsuit, then

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before disclosing any Confidential Material to a current or former employee,

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consultant, advisor, or agent of that entity, the Receiving Party’s counsel must confer

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with counsel for the Producing Party.

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Persons Receiving Confidential Information Must Sign Exhibit A.

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Counsel for each party shall advise all persons to whom Confidential Material is

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disclosed pursuant to this Order of the existence of this Order and shall provide all
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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such persons (other than the Court and its staff) with a copy of this Order. Counsel

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shall also require such persons to execute the Affidavit attached as Exhibit A, prior to

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the disclosure of Confidential Material.
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Duties in the Event of Unauthorized Disclosures.

It shall be the

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obligation of counsel, upon learning of any unauthorized disclosure or threatened

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unauthorized disclosure of Confidential Information, or any other breach or threatened

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breach of the provisions of this Order, to promptly notify counsel for the Producing

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Party.

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circumstances of the disclosure in order to permit the producing party to understand

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and take appropriate steps. Each party and its counsel agree to take reasonable and

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good-faith efforts to contain or limit any breach promptly upon receiving notice of it,

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and to make reasonable and good-faith attempts to retrieve any unauthorized

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disclosure of documents or information. This provision does not limit the producing

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party’s entitlement to damages resulting from any breach of this Order.

The notification shall be supplemented with reasonable details of the

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VI.

Authorized Uses of Confidential Material

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19.

Confidential Material shall only be used for the purpose of litigating the

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above-captioned lawsuit and may not be used in other lawsuits.
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Persons having knowledge of Confidential Material and information due

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to their participation in the conduct of this litigation shall use such knowledge and

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information only as permitted herein, and shall not disclose such Confidential

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Material, their contents or any portion or summary thereof to any person(s) not

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involved in the conduct of this litigation.

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21.

If any person having access to the Confidential Material herein shall

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violate this Order, he/she may be subject to sanctions by the Court and may be liable

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to pay for the damages caused by his/her violation.

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VII. Challenges to the Designation of Confidential Material

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22.

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Any party or interested member of the public may move the Court to

modify the designation of any documents or information produced in this litigation
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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(either to include additional protection with respect to confidentiality or to remove a

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confidential designation). Before making such a motion, the party or an interested

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member of the public shall first attempt to resolve such dispute with the producing

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party’s counsel. Pending resolution of any challenges to the designation of documents

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or information, the material at issue shall continue to be treated as Confidential

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Material until ordered otherwise by the Court. The burden shall be on the party

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seeking to modify the designation to show that the producing party’s designation is

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inappropriate.

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VIII. Withholding of Information
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Redactions. The Parties may redact (1) information that is privileged or

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protected from discovery as work product or by reason of any other applicable

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privilege or immunity; (2) information subject to non-disclosure obligations imposed

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by governmental authorities, law or regulation (e.g., protected personal information);

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and (3) sensitive, non-relevant information, including but not limited to personally

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identifiable information, trade secrets, or information regarding products, data, or

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people. Redactions of emails will not redact the names of recipients or the subject line

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of the emails, unless the subject line is itself privileged or contains the sensitive

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information described above, in which case only so much of the subject line will be

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redacted as may be needed. The Parties will produce redacted documents in TIFF

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format (or searchable PDF if production format dictates; or in native format for file

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types that do not convert well to TIFF/PDF, such as Excel files) with corresponding

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searchable OCR text and the associated metadata for the document, ensuring the

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redacted content is fully protected from disclosure.

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IX.

Confidential Material In Filings, Hearings, and Trial

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Confidential Material in Filings. Without written permission from the

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Producing Party or court order secured after appropriate notice to all interested

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persons, a party may not file Confidential Material in the public record in this action

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(or in any other action, such as an appeal). A party that seeks to file under seal any
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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Confidential Material must first obtain a sealing order in compliance with Eastern

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District of California Local Rule 141. Confidential Material may only be filed under

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seal in a manner prescribed by the Court for such filings.

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Manner of Sealing. In the event Confidential Materials or portions of

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transcripts are sealed as confidential by the Court or as described in paragraph (24)

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above, they shall be filed in an envelope bearing the following designation when

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deposited:

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CONFIDENTIAL

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IN ACCORDANCE WITH THE CONFIDENTIALITY ORDER OF THE

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COURT, THE CONTENTS OF THIS ENVELOPE SHALL BE TREATED AS

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CONFIDENTIAL AND MUST NOT BE SHOWN TO A PERSON OTHER THAN

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THE COURT, ATTORNEYS IN THIS CASE, OR TO PERSONS ASSISTING

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THOSE ATTORNEYS.

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Confidential Material in Hearings and Trial. The provisions of this

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Order shall not affect, and this Order does not limit, the admissibility of Confidential

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Material (or references to that material) as evidence at trial, or during a hearing or

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similar proceeding in this action.

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information contained therein at any hearing that is open to the public, the party

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seeking to use the Confidential Material must give at least seven (7) days advance

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notice to the producing party of the intent to use the Confidential Material so that the

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producing party may seek an appropriate Court Order to protect the Confidential

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Material.

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Continuing Effect of this Order and Duty to Destroy

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This Order shall continue to be binding throughout and after the

Prior to using Confidential Material or the

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conclusion of this litigation, including all appeals. Within thirty (30) days of settlement

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or final adjudication, including the expiration or exhaustion of all rights to appeal or

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petitions for extraordinary writs, each party or non-party to whom any materials were

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produced shall, without further request or direction from the Producing Party,
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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promptly destroy all documents, items or data received including, but not limited to,

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copies or summaries thereof, in the possession or control of any expert or employee.

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This requirement to destroy includes all documents, not only those documents

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designated as Confidential Material. The Receiving Party shall submit a written

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certification to the Producing Party by the 30-day deadline that (1) confirms the

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destruction/deletion of all Confidential Material, including any copies of Confidential

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Materials provided to persons required to execute Exhibit A (Affidavit), and (2)

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affirms the Receiving Party has not retained any copies, abstracts, compilations,

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summaries or any other format reproducing or capturing any of the Confidential

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Material. Notwithstanding this provision, outside counsel is entitled to retain an

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archival copy of filings, depositions, and deposition exhibits.

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XI.

Procedure if Confidential Material is Required to be Produced

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If any person receiving documents covered by this Order is served with a

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subpoena, order, interrogatory, document, or civil investigative demand (collectively,

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a “Demand”) issued in any other action, investigation, or proceeding, and such

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Demand seeks material that was produced or designated as Confidential Material by

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someone other than the Receiving Party, the Receiving Party shall give prompt written

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notice by hand or electronic transmission within five (5) business days of receipt of

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such Demand to the party or non-party who produced or designated the material as

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Confidential Material, and shall object to the production of such materials on the

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grounds of the existence of this Order. At the request of the party or non-party who

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produced or designated the material as Confidential Material, the Receiving Party shall

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refuse to comply with the Demand unless (a) ordered to do so by a court with

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jurisdiction over the Receiving Party; or (b) released in writing by the party or non-

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party who designated the material as Confidential Material. The burden of opposing

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the enforcement of the Demand shall fall upon the party or non-party who produced

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or designated the material as Confidential Material. Compliance by the Receiving

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Party with any order of a court of competent jurisdiction, directing production of any
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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Confidential Material, shall not constitute a violation of this Order.

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XII. Application of this Order to Productions by Third Parties

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This Order may be used by third parties producing documents in

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connection with this action. Third parties may designate information as “Confidential”

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or “Highly Confidential – Attorneys’ Eyes Only”.

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30.

If a third party produces (or intends to produce) documents and does not

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designate (or does not intend to designate) those documents as Confidential Material,

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then any party to this action may seek to designate that third party’s documents or

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categories of documents as Confidential Material. In that case, it will be the burden

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of the party seeking protected status to move for a court order designating the materials

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as Confidential Material after the Parties confer.

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31.

In the event additional parties join or intervene in this litigation, the newly

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joined party(ies) shall not have access to Confidential Material until its/their counsel

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has executed and, at the request of any party, filed with the Court the agreement of

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such party(ies) and such counsel to be fully bound by this Order.

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32.

The Parties agree that nothing in this Order shall be deemed to limit the

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extent to which counsel for the Parties may advise or represent their respective clients,

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conduct discovery, prepare for trial, present proof at trial, including any document

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designated Confidential Material as set forth herein, or oppose the production or

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admissibility of any information or documents which have been requested.

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33.

This Order shall remain in full force and effect until such time as it is

modified, amended, or rescinded by the Court.

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XIII. No Admissions

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34.

Neither entering into this Stipulation for Protective Order, nor receiving

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any documents or other information designated as “Confidential,” shall be construed

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as an agreement or admission (1) that any document or information designated as

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“Confidential” is in fact Confidential Information; (2) as to the correctness or truth of

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any allegation made or position taken relative to any matter designated as
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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

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“Confidential”; or (3) as to the authenticity, competency, relevancy, or materiality of

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any information or document designated as “Confidential.”

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XIV. Modification – Further Agreements

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35.

Nothing contained herein shall preclude any party from seeking from the

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Court, modification of this Stipulated Protective Order upon proper notice or shall

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preclude the Parties from entering into other written agreements designed to protect

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Confidential Information.

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XV. Counterparts

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36.

This Stipulation for Protective Order may be executed in counterparts,

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each of which shall be deemed an original, and which together shall constitute one

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instrument.

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IT IS SO STIPULATED.

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DATED: April 15, 2024

By: /s/Narak Mirzaie
Narak Mirzaie

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Attorneys for Plaintiff DIANE BOYD

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M LAW ATTORNEYS, APC

DATED: April 15, 2024

OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
By: /s/ James T. Conley
James T. Conley
Jane A. Rothbaler
Attorneys for WALMART INC.

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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

[PROPOSED] ORDER

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The Court has reviewed the Stipulation Regarding Production of Confidential

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Documents and Proprietary Information filed by Defendant WALMART INC.,

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(“Defendant”) and Plaintiff DIANE L. BOYD (“Plaintiff”) (collectively “the Parties”),

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through their counsel of record, requesting that the Court enter an Order.

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IT IS SO ORDERED.

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Dated:
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May 8, 2024
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION

Exhibit A

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ACKNOWLEDGMENT OF RECEIPT OF PROTECTIVE ORDER

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REGARDING CONFIDENTIAL INFORMATION AND AGREEMENT TO

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BE BOUND THEREBY

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I hereby acknowledge receipt of and that I have read a copy of the Stipulation

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for Protective Order and Order (the “Order”), which I understand was made on

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_________________, 2024, in the action entitled Diane Boyd v. Walmart Inc., et al.,

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Case No. 2:24-cv-00275-DJC-DMC, USDC, Eastern District of California. I agree

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that I will be bound by the provisions of the Order with respect to any Confidential

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Information provided to me under the terms thereof. I agree that, if I receive any

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Confidential Information, I will not make any copies thereof nor disclose such

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Confidential Information except as permitted by the Order. I further understand that

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if I fail to comply with the terms of the Order, I may be subject to sanctions by the

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Court, and I hereby consent to personal jurisdiction in the State of California with

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respect to any matter relating to or arising out of the Order.

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Executed this

day of

2024, at

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Signature

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Name:

________________________________________

Affiliation: ________________________________________

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Address:

________________________________________
________________________________________

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STIPULATION AND ORDER REGARDING PRODUCTION OF CONFIDENTIAL DOCUMENTS AND
PROPRIETARY INFORMATION
61651354.v1-OGLETREE