Sanchez v. Home Depot U.S.A., Inc.

Filing 24

STIPULATED PROTECTIVE ORDER. Signed by Judge Thelton E. Henderson on 10/10/2013. (tmi, COURT STAFF) (Filed on 10/10/2013)

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1 SPENCER C. YOUNG, State Bar No. 236593 2 LAW OFFICES OF SPENCER C. YOUNG 3 1300 Clay Street, Suite 600 Oakland, CA 94612-1427 510.645.1585 4 Telephone: Facsimile: 510.645.1586 5 Attorney for Plaintiff 6 NEREIDA SANCHEZ 7 8 9 10 11 12 GREGORY C. CHENG, State Bar No. 226865 JILL V. CARTWRIGHT, State Bar No. 260519 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Steuart Tower, Suite 1300 One Market Plaza San Francisco, CA 94105 Telephone: 415.442.4810 Facsimile: 415.442.4870 13 Attorneys for Defendant HOME DEPOT U.S.A., INC. 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 18 NEREIDA SANCHEZ, 21 22 STIPULATED PROTECTIVE ORDER Plaintiff, 19 20 Case No. C-13-02333 TEH vs. IT IS SO ORDERED AS MODIFIED HOME DEPOT U.S.A., INC.; and DOES 1100, Defendant. Complaint Filed: Trial Date: April 8, 2013 August 19, 2014 23 24 25 26 27 28 Case No. C-13-02333 TEH STIPULATED PROTECTIVE ORDER 1 IT IS HEREBY STIPULATED by and between Plaintiff Nereida Sanchez (hereinafter 2 referred to as “Plaintiff” and/or “Sanchez”) and Defendant Home Depot U.S.A., Inc. (hereinafter 3 referred to as “Defendant” and/or “Home Depot”), through their respective attorneys of record, that 4 a Protective Order be entered by this Court as follows: 5 This Stipulation and Protective Order shall be applicable to and shall apply to the production 6 and exchange of all document requests and documents, interrogatories and answers to 7 interrogatories, depositions, request for admissions, and responses to requests for admissions, 8 exhibits, and pleadings and all other information exchanged and furnished in this Action by the 9 Parties that the parties customarily treat as confidential, proprietary, and/or a trade secret as defined 10 by California Civil Code Section 3426.1. 11 1. SCOPE 12 (a) The parties acknowledge that discovery may require disclosure of information that is 13 private and personal or confidential and proprietary, specifically personnel records, personnel 14 policies, employment offers, competitive analyses, income statements, employee, client, or 15 customer personal information (including, but not limited to medical, age, and contact information), 16 medical records, and financial records and statements, along with other trade secret information as 17 defined in California Civil Code Section 3426.1. As a result, the parties agree to enter into a 18 Protective Order on the following terms to ensure the continuing confidentiality of such 19 information. The parties further acknowledge that this Order does not confer blanket protections on 20 all disclosures or responses to discovery and that the protection it affords extends only to the limited 21 information or items that are entitled under the applicable legal principles to treatment as 22 confidential. 23 (b) This Protective Order shall limit the use or disclosure of documents, deposition 24 testimony, and related information which are or which embody or disclose any information falling 25 with the scope of Paragraph (1)(a) and designated hereunder as “Confidential,” and shall apply to: 26 (i) All such documents, including those produced by third parties, designated as 27 “Confidential” in accordance with the terms of this Protective Order and the applicable legal 28 standards; 1 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 (ii) Portions of deposition testimony and transcripts and exhibits thereto which 2 include, refer or relate to any Confidential Information; 3 (iii) All information, copies, extracts and complete or partial summaries prepared 4 or derived from Confidential Information; and 5 (iv) Portions of briefs, memoranda or any writing filed with or otherwise supplied 6 to the Court, which include or refer to any such Confidential Information. 7 (c) Any person designating documents, testimony, or other information as 8 “Confidential” hereunder asserts that he or she believes in good faith that such material is 9 Confidential Information which falls within the scope of Section (1)(a) and is not otherwise 10 available to the public generally. Each party or non-party that designates information or items for 11 protection under this Order must take care to limit any such designation to specific material that 12 qualifies under the appropriate standards. A Designating Party must take care to designate for 13 protection only those parts of material, documents, items, or oral or written communications that 14 qualify so that other portions of the material, documents, items, or communications for which 15 protection is not warranted are not swept unjustifiably within the ambit of this Order. 16 2. DESIGNATION OF DOCUMENTS AND DEPOSITIONS 17 (a) Designation of a document as “Confidential” shall be made by stamping or writing 18 CONFIDENTIAL on the document(s). Alternatively, the parties may designate documents as 19 “Confidential” by producing the documents with a letter designating the documents by Bates 20 number as “Confidential.” The parties shall make all reasonable effort to designate as 21 “Confidential” only those documents that they reasonably believe constitute personnel records, 22 personnel policies, employment offers, competitive analyses, income statements, employee, client 23 or customer personal information, medical records, financial records and statements, and trade 24 secret information as defined in California Civil Code Section 3426.1. The failure to designate 25 documents as “Confidential” at the time of production shall not constitute a waiver of the protection 26 of this Order and any party may, at any time up to 30 days before the actual trial date in this action, 27 designate any documents or information produced as “Confidential” that have not as yet been so 28 designated. Stamping the legend “Confidential” on the cover of any multi-page document shall 2 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 designate all pages of the document as confidential, unless otherwise indicated by the Designating 2 Party, but only if the entire document is produced in a bound or otherwise intact manner. 3 (b) Designation of a deposition or other pretrial testimony, or portions thereof, as 4 “Confidential” shall be made by a statement on the record by counsel for the party or other person 5 making the claim of confidentiality at the time of such testimony. The portions of depositions so 6 designated as “Confidential” shall be taken only in the presence of persons qualified to receive such 7 information pursuant to the terms of this Protective Order: the parties and their attorneys and staff, 8 the court reporter, videographer, the deponent, and the deponent’s attorney. Failure of any other 9 person to comply with a request to leave the deposition room will constitute sufficient justification 10 for the witness to refuse to answer any question calling for disclosure of Confidential Information 11 so long as persons are in attendance who are not entitled by this Protective Order to have access to 12 such information. The parties may, but need not in order to designate material as Confidential 13 Information, instruct the court reporter to segregate such portions of the deposition in a separate 14 transcript designated as “Confidential.” Portions of such deposition transcripts shall be clearly 15 marked as “Confidential” on the cover or on each page, as appropriate. 16 (c) Any party may designate documents produced or portions of depositions taken as 17 containing Confidential Information even if not initially marked as “Confidential” in accordance 18 with the terms of this Protective Order by so advising counsel for each other party in writing and by 19 reproducing said documents with the required confidential designation. Thereafter, each such 20 document or transcript shall be treated in accordance with the terms of this Protective Order; 21 provided, however, that there shall be no liability for any disclosure or use of such documents or 22 transcripts, or the Confidential Information contained therein, which occurred prior to actual receipt 23 of such written notice. Any person who receives actual notice of any such designation of 24 previously produced documents or deposition transcripts as containing Confidential Information 25 shall thereafter treat such information as if it had been designated as “Confidential” at the time he, 26 she, or it first received it in connection with this matter. 27 28 (d) Inadvertent failure to designate Confidential Information shall not be construed as a waiver, in whole or in part, and may be corrected by the producing party by designating documents 3 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 produced or portions of depositions taken as containing Confidential Information, even if not 2 initially marked as “Confidential,” in accordance with the terms of this Protective Order and, 3 specifically, Paragraph 2(c) above. 4 3. LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL INFORMATION 5 (a) No Confidential Information shall be disclosed by anyone receiving such 6 information to anyone other than those persons designated herein. In no event shall Confidential 7 Information be used, either directly or indirectly, by anyone receiving such information for any 8 business, commercial or competitive purpose or for any purpose whatsoever other than the direct 9 furtherance of the litigation of this action in accordance with the provisions of this Protective Order. 10 (b) Confidential Information shall not be disclosed by any person who has received such 11 information through discovery in this action to any other person, except to: 12 (i) The parties; 13 (ii) Attorneys of record for the parties and their firms’ associates, clerks and 14 other employees involved in the conduct of this litigation, and any court reporters, videographers, 15 or interpreters engaged to assist the parties in discovery; 16 (iii) Home Depot’s, its subsidiaries’, or its affiliates’ in-house counsel; 17 (iv) Non-party experts and consultants engaged by counsel for the purpose of 18 preparing or assisting in this litigation, and those experts’ respective clerks and employees involved 19 in assisting them in this litigation, to the extent deemed necessary by counsel; 20 (v) The Court, its officers, Court reporters and similar personnel, provided 21 further that Confidential Information lodged with the Court under seal is subject to further 22 evaluation by the Court; 23 (vi) Any person as to which it is apparent from the face of a document was either 24 an author, recipient, had knowledge of the contents therein, or was otherwise entitled to view the 25 Confidential Information prior to the intended disclosure in this action; and 26 27 28 (vii) Any other potential witnesses whose testimony may be used in connection with the present case who has complied with Paragraph 3(c) immediately below. (c) Before any person described in Paragraphs 3(b)(iv) and (vii) receives or is shown 4 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 any document or information which has been designated as Confidential, such person shall be given 2 a copy of this Protective Order and shall agree in writing, in the form of the Acknowledgment and 3 Agreement attached hereto as Exhibit A, to be bound by the terms hereof. The original of each 4 such Acknowledgment and Agreement shall be maintained by counsel and, if a witness appears at 5 deposition or at trial and represents that he or she previously executed an Acknowledgment, it shall 6 be produced for inspection by opposing counsel upon request. Any counsel may require the other 7 counsel to provide a copy of the Acknowledgment and Agreement signed by a witness at a 8 deposition before the witness is deposed with regard to any Confidential Information. 9 (d) Nothing in this Protective Order shall be construed to require execution of the 10 written Acknowledgment and Agreement referred to in Paragraph 3(c) above, or to prevent 11 disclosure of Confidential Information, by the party producing and designating such Confidential 12 Information, or by any employee of such party. 13 (e) The substance or content of Confidential Information, as well as all notes and 14 memoranda relating thereto, shall not be disclosed to anyone other than as set forth in Paragraphs 15 3(b)(i)-(vii) above. 16 4. FILING DOCUMENTS UNDER SEAL 17 (a) A Party may not file in the public record in the action any document designated as 18 Confidential or that contains Confidential Information. If a Party wishes to submit a document to 19 the Court which the other Party has designated as Confidential or which contains Confidential 20 Information and which has not been successfully challenged under Paragraph 5 below, the 21 submitting Party shall comply with the procedures set forth in Civil Local Rule 79-5, General Order 22 62, and must also comply with Federal Rule of Civil Procedure 26(c)(1). Protected Material may 23 only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected 24 Material at issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request 25 establishing that the Protected Material at issue is privileged, protectable as a trade secret, or 26 otherwise entitled to protection under the law. If a Receiving Party's request to file Protected 27 Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then the Receiving 28 Party may file the information in the public record pursuant to Civil Local Rule 79-5(e) unless 5 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 otherwise instructed by the court. 2 The Parties agree and recognize that Confidential Information or any paper containing Confidential 3 Information cannot be filed under seal based solely upon this stipulated Protective Order. CHALLENGE TO CONFIDENTIALITY DESIGNATION 4 5. 5 Any party that wishes to challenge the designation of a document or other information as 6 “Confidential” must identify the documents or information for which it is challenging the 7 designation within 30 days after their production. The Challenging Party shall initiate the dispute 8 resolution process by providing written notice of each designation it is challenging and describing 9 the basis for each challenge. To avoid ambiguity as to whether a challenge has been made, the 10 written notice must recite that the challenge to confidentiality is being made in accordance with this 11 specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in 12 good faith and must begin the process by meeting and conferring in accordance with Local Rule 37- 13 1. In conferring, the Challenging Party must explain the basis for its belief that the confidentiality 14 designation was not proper and must give the Designating Party an opportunity to review the 15 designated material, to reconsider the circumstances, and, if no change in designation is offered, to 16 explain the basis for the chosen designation. A Challenging Party may proceed to the next stage of 17 the challenge process only if it has engaged in this meet and confer process first or establishes that 18 the Designating Party is unwilling to participate in the meet and confer process in a timely manner. 19 The Designating Party may, for good cause shown, bring a motion before the Court under 20 Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) requesting that the Court 21 confirm the designation of any document or information as “Confidential.” Each such motion must 22 be accompanied by a competent declaration affirming that the movant has complied with the meet 23 and confer requirements imposed in the preceding paragraph. The party asserting the designation as 24 “Confidential” shall have the burden of establishing good cause for the designation. However, the 25 Court shall be authorized to award the moving party attorneys’ fees as a sanction if the challenge to 26 the “Confidential” designation was made in bad faith or was frivolous. \ Pending resolution of any 27 dispute concerning such designation, all parties and persons governed by this Protective Order shall 28 treat all documents and information previously designated as “Confidential” as protected from 6 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 further disclosure by this Protective Order. 2 6. SURVIVAL OF ORDER - RETURN OF DOCUMENTS 3 (a) The provisions of this Order shall continue in effect until otherwise ordered by the 4 Court, or after notice and an opportunity to be heard is afforded to the parties to this action. The 5 final determination or settlement of this action shall not relieve any person who has received 6 Confidential Information or agreed to be bound by the terms of this Protective Order of his, her, or 7 its obligations under this stipulation and Order. The Court shall retain jurisdiction after such final 8 determination or settlement to enforce the provisions of this Order. Upon completion of the 9 litigation, all documents (including copies of documents) containing Confidential Information shall 10 be destroyed or returned to counsel for the producing party, except that (a) documents on which any 11 person has made notations may be destroyed and not returned, and (b) the parties’ respective 12 attorneys of record may retain one copy of each such document for use in connection with any 13 disputes which may arise under the Court’s retention of jurisdiction as provided for herein. Within 14 sixty days (60) of the conclusion of this litigation, the attorneys for the receiving party shall provide 15 the attorneys for the producing party a certificate representing that such return or destruction was 16 made. 17 (b) Except as provided in Paragraphs 4 or 6 hereof, documents or things containing the 18 other party’s Confidential Information shall at all times be in the physical possession of those 19 persons qualifying under Paragraph 3 hereunder, or kept by counsel of record at the premises 20 regularly maintained by such counsel of record as and for their respective law offices. USE OF DOCUMENTS AT TRIAL 21 7. 22 This Stipulation and Protective Order, except as provided in Paragraph 4, shall not apply to 23 information designated or marked Confidential hereunder which is used at any evidentiary hearing 24 or trial in this action. The parties hereby reserve their rights to use, or seek to limit the disclosure 25 of, confidential information at any such hearing or trial. USE OF OWN DOCUMENTS BY PRODUCING PARTY 26 8. 27 Nothing in this Protective Order shall limit the use by any party, person or entity of his, her, 28 or its own document or information for legitimate business purposes unrelated to this litigation, 7 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 even if such documents or information have been designated as “Confidential.” 2 9. APPLICATIONS TO COURT 3 (a) This Protective Order shall not preclude or limit any party’s right to oppose or object 4 to discovery on any ground which would be otherwise available. This Protective Order shall not 5 preclude or limit any party’s right to seek in camera review or to seek further and additional 6 protection against or limitation upon production or dissemination of information produced in 7 response to discovery, including documents and their contents. 8 (b) Any person to or by whom disclosure or inspection is made in violation of this 9 Protective Order, and who has knowledge of this Protective Order, shall be bound by the terms 10 hereof. 11 (c) The parties hereto, and all other persons who receive Confidential Information 12 pursuant hereto, agree that any party or other person injured by a violation of this Order does not 13 have an adequate remedy at law and that an injunction against such violation is an appropriate 14 remedy. In the event any person shall violate or threaten to violate any terms of this Order, the 15 parties agree that the aggrieved party may immediately apply to obtain injunctive relief against any 16 such person. In the event the aggrieved party shall do so, the responding person subject to the 17 provisions of this Order shall not employ as a defense thereto the claim that the aggrieved party has 18 an adequate remedy at law. Any persons subject to the terms of this Order agree that the Court 19 shall retain jurisdiction over it and them for the purposes of enforcing this Order, including but not 20 limited to issuing an injunction. In addition to injunctive relief, as specified herein, the Court may 21 impose monetary and/or issue sanctions, as well as other relief deemed appropriate under the 22 circumstances for a violation of this Protective Order. 23 (d) If any deponent required under the terms of this Protective Order to execute the 24 written Acknowledgment and Agreement described in Paragraph 3(c) above refuses to do so, the 25 parties may complete the deposition on other matters and/or adjourn it and move the Court for any 26 appropriate relief, including (without limitation) relief from this Protective Order as to that 27 deponent, or an order that the deponent shall execute the written agreement described in Paragraph 28 3(c) above, or an order that deponent shall be bound by the terms of this Protective Order. Any 8 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH 1 non-party whose Confidential Information is the subject of such a motion shall be given notice 2 thereof. AGREEMENT TO COOPERATE 3 10. 4 The parties hereto and their respective attorneys of record agree that, when one party’s 5 attorney requests a deponent to sign the written Acknowledgment and Agreement described in 6 Paragraph 3(c) above, the other party’s attorney will join in such request, unless that attorney has a 7 good faith basis for refusing to join in such a request; provided, however, that this requirement shall 8 not apply with respect to any deponent who is represented at his or her deposition by an attorney of 9 record for any party hereto (including any member or associate of their respective law firms). An 10 attorney’s request to sign such Acknowledgment pursuant to this Paragraph shall not be construed 11 to constitute legal advice to the deponent, but shall and may be stated to be simply a request to 12 facilitate discovery in this action. NO ADMISSIONS 13 11. 14 Neither entering into this Stipulation for Protective Order, nor receiving any documents or 15 other information designated as “Confidential” shall be construed as an agreement or admission: (1) 16 that any document or information designated as “Confidential” is in fact Confidential Information; 17 (2) as to the correctness or truth of any allegation made or position taken relative to any matter 18 designated as “Confidential”; or (3) as to the authenticity, competency, relevancy or materiality of 19 any information or document designated as “Confidential.” NO WAIVER OF PRIVILEGES OR OBJECTIONS TO ADMISSIBILITY 20 12. 21 Nothing in this Protective Order shall be construed as requiring disclosure of Confidential 22 Information, including, but not limited to, materials subject to protection under the attorney-client 23 privilege and/or attorney work product doctrine, the trade secrets privilege, or under any other 24 applicable privileges or rights of privacy, or requiring disclosure of Confidential Information that is 25 otherwise beyond the scope of permissible discovery. Further, nothing in this Protective Order 26 shall be construed as a waiver by a party of any objections that might be raised as to the 27 admissibility at trial of any evidentiary materials. 28 / / / 9 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH DISCLOSURE IN VIOLATION OF ORDER 1 13. 2 If any Confidential Information is disclosed to any person other than in the manner 3 authorized by this Protective Order, the party responsible for the disclosure must immediately, in 4 writing, notify the opposing party and the Designating Party of all pertinent facts relating to such 5 disclosure, and without prejudice to the rights and remedies of the Designating Party, make every 6 effort to prevent further unauthorized disclosure. MODIFICATION - FURTHER AGREEMENTS 7 14. 8 Nothing contained herein shall preclude any party from seeking from a Court modification 9 of this Stipulated Protective Order upon proper notice, nor shall anything contained herein be 10 construed as to preclude the parties from entering into other written agreements designed to protect 11 Confidential Information. COUNTERPARTS 12 15. 13 This Stipulation for Protective Order may be executed in counterparts, each of which shall 14 be deemed an original and which together shall constitute one instrument. 15 16 DATED: October 7, 2013 LAW OFFICES OF SPENCER C. YOUNG 17 18 BY: /s/ Spencer Young SPENCER YOUNG 19 20 Attorney For Plaintiff NEREIDA SANCHEZ 21 22 DATED: October 7, 2013 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 23 24 By: 25 /s/ Jill Cartwright GREGORY C. CHENG JILL V. CARTWRIGHT 26 27 Attorneys for Defendant HOME DEPOT, U.S.A., INC 28 10 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH SIGNATURE ATTESTATION 1 2 Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document 3 has been obtained from the other signatories. 4 DATED: October 7, 2013 5 By: /s/ Jill Cartwright Jill V. Cartwright 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 11 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH [PROPOSED] ORDER 1 2 GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED THAT the 3 provisions of the concurrently-filed stipulation between the parties regarding the use and protection 4 of Confidential Information (the “Stipulated Protective Order”) shall be entered as the Order of the 5 Court and be binding upon the parties. The Court further orders that, consistent with Paragraph 4 of 6 the parties’ Stipulated Protective Order, the parties file documents under seal which are subject to 7 this Stipulated Protective Order and have not been successfully challenged by the opponent. In all 8 other respects, the parties must comply with the procedures set forth in Local Rule 79-5, General 9 Order 62 and must also comply with Federal Rule of Civil Procedure 26(c)(1). 10 PURSUANT TO STIPULATION, IT IS SO ORDERED. 10/10 , 2013 NO 16 J RT 17 rson . Hende elton E udge Th H ER 18 FO 15 R NIA DERED THE HON. S SO OR E. HENDERSON I THELTONIED IT JUDGE OF THEODIF AS M UNITED STATES DISTRICT COURT LI 14 DATED: UNIT ED 13 S DISTRICT TE C TA RT U O S 12 A 11 N F D IS T IC T O R C 19 20 21 22 23 24 25 26 27 28 12 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 I, ________________________________________, hereby certify that: 4 1. My present address is _____________________________. 5 2. My present employer is ___________________________. 6 3. My present occupation or job description is _____________________. 7 4. I have received a copy of the Protective Order in the above-captioned case and agree 8 to be bound by the terms of the Protective Order. 9 5. I have carefully read and understand the provisions of the Protective Order. 10 6. I will hold in confidence and not disclose to anyone not qualified under the 11 Protective Order, any Confidential Information or any portion or substance thereof provided to me 12 in the course of this litigation. 13 7. I will return all materials containing Confidential Information or any portions or 14 copies, summaries, abstracts or indices thereof, which come into my possession, and documents or 15 things that I prepared relating thereto and containing such Confidential Information, to counsel for 16 the party by whom I am retained or employed, or to counsel by whom I am retained or employed, 17 when my services in this matter have been concluded. 18 8. I understand that if I violate the provisions of this Protective Order, I may be subject 19 to sanctions by the Court, among other things. 20 9. I hereby submit to the jurisdiction of the United States District Court for the 21 Northern District of California for the purpose of enforcement of this Protective Order against me. 22 I declare under penalty of perjury under the laws of the State of California and the United 23 States of America that the foregoing is true and correct. 24 25 Dated:_________________ Signature:_________________________________ 26 27 28 15665792.2 13 STIPULATED PROTECTIVE ORDER Case No. C-13-02333 TEH

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