The Estate of Vasilios Katsouras et al v. City of Union City et al
Filing
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CONFIDENTIAL STIPULATED PROTECTIVE ORDER. Signed by Judge Richard Seeborg on 5/31/17. (cl, COURT STAFF) (Filed on 5/31/2017)
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Attorneys for Defendants
CITY OF UNION CITY; UNION CITY POLICE
DEPARTMENT
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UNITED STATES DISTRICT COURT
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180 Montgomery Street, Suite 1200
San Francisco, California 94104
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
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DALE L. ALLEN, JR., State Bar No. 145279
dallen@aghwlaw.com
KEVIN P. ALLEN, State Bar No. 252290
kallen@aghwlaw.com
PHILIP J. DOWNS, JR., State Bar No. 302939
pdowns@aghwlaw.com
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
180 Montgomery Street, Suite 1200
San Francisco, CA 94104
Telephone:
(415) 697-2000
Facsimile:
(415) 813-2045
NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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THE ESTATE OF VASILIOS
KATSOURAS; KLEARCHOS
KATSOURAS, an individual; and
NANCY KATSOURAS, an individual,
Case No. 3:17-cv-01075-RS
CONFIDENTIAL STIPULATED
PROTECTIVE ORDER
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Plaintiff,
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v.
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CITY OF UNION CITY; UNION CITY
POLICE DEPARTMENT; and DOE
OFFICERS 1-20,
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Defendants.
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1.
PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action are likely to involve production of
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confidential, proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the parties hereby stipulate to and petition the court to enter the following
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Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket
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protections on all disclosures or responses to discovery and that the protection it affords from
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public disclosure and use extends only to the limited information or items that are entitled to
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confidential treatment under the applicable legal principles. The parties further acknowledge, as
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set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file
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confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
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followed and the standards that will be applied when a party seeks permission from the court to
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file material under seal.
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2.
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180 Montgomery Street, Suite 1200
San Francisco, California 94104
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
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DEFINITIONS
2.1
Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
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
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of Civil Procedure 26(c).
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2.3
Counsel (without qualifier): Outside Counsel of Record and House Counsel (as
well as their support staff).
2.4
Designating Party: a Party or Non-Party that designates information or items that
it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
2.5
Disclosure or Discovery Material: all items or information, regardless of the
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medium or manner in which it is generated, stored, or maintained (including, among other things,
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testimony, transcripts, and tangible things), that are produced or generated in disclosures or
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responses to discovery in this matter.
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2.6
Expert: a person with specialized knowledge or experience in a matter pertinent
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to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as
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a consultant in this action.
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2.7
House Counsel: attorneys 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.
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2.9
Outside Counsel of Record: attorneys who are not employees of a party to this
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action but are retained to represent or advise a party to this action and have appeared in this
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action on behalf of that party or are affiliated with a law firm which has appeared on behalf of
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that party.
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2.10
consultants, retained experts, and Outside Counsel of Record (and their support staffs).
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2.11
Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
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2.12
Professional Vendors: persons or entities that provide litigation support services
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Party: any party to this action, including all of its officers, directors, employees,
(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and
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organizing, storing, or retrieving data in any form or medium) and their employees and
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subcontractors.
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2.13
Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
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2.14
Receiving Party: a Party that receives Disclosure or Discovery Material from a
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Producing Party.
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3.
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SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material
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(as defined above), but also (1) any information copied or extracted from Protected Material; (2)
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all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
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conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
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However, the protections conferred by this Stipulation and Order do not cover the following
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information: (a) any information that is in the public domain at the time of disclosure to a
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Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as
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a result of publication not involving a violation of this Order, including becoming part of the
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public record through trial or otherwise; and (b) any information known to the Receiving Party
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prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who
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obtained the information lawfully and under no obligation of confidentiality to the Designating
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Party. 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
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this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court
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order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all
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claims and defenses in this action, with or without prejudice; and (2) final judgment herein after
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the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this
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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.
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DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection. Each Party
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or Non-Party that designates information or items for protection under this Order must take care
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to limit any such designation to specific material that qualifies under the appropriate standards.
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The Designating Party must designate for protection only those parts of material, documents,
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items, or oral or written communications that qualify – so that other portions of the material,
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documents, items, or communications for which protection is not warranted are not swept
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unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations that are
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shown to be clearly unjustified or that have been made for an improper purpose (e.g., to
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unnecessarily encumber or retard the case development process or to impose unnecessary
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expenses and burdens on other parties) expose the Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it designated for
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protection do not qualify for protection, that Designating Party must promptly notify all other
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Parties that it is withdrawing the mistaken designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in this Order
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(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
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Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
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designated before the material is disclosed or produced.
Designation in conformity with this Order requires:
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(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
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Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only
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a portion or portions of the material on a page qualifies for protection, the Producing Party also
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must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
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margins). A Party or Non-Party that makes original documents or materials available for
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inspection need not designate them for protection until after the inspecting Party has indicated
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which material it would like copied and produced. During the inspection and before the
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designation, all of the material made available for inspection shall be deemed
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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and
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produced, the Producing Party must determine which documents, or portions thereof, qualify for
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protection under this Order. Then, before producing the specified documents, the Producing
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Party must affix the “CONFIDENTIAL” legend to each page that contains Protected Material. If
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only a portion or portions of the material on a page qualifies for protection, the Producing Party
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also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the
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180 Montgomery Street, Suite 1200
San Francisco, California 94104
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
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margins).
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(b) for testimony given in deposition or in other pretrial or trial proceedings, that the
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Designating Party identify on the record, before the close of the deposition, hearing, or other
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proceeding, all protected testimony.
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(c) for information produced in some form other than documentary and for any other
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tangible items, that the Producing Party affix in a prominent place on the exterior of the
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container or containers in which the information or item is stored the legend
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“CONFIDENTIAL.” If only a portion or portions of the information or item warrant protection,
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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
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right to secure protection under this Order for such material. Upon timely correction of a
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designation, the Receiving Party must make reasonable efforts to assure that the material is
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treated in accordance with the provisions of this Order.
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6.
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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a designation of
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
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burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
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challenge a confidentiality designation by electing not to mount a challenge promptly after the
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original designation is disclosed.
6.2
Meet and Confer. The Challenging Party shall initiate the dispute resolution
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process by providing written notice of each designation it is challenging and describing the basis
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for each challenge. To avoid ambiguity as to whether a challenge has been made, the written
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notice must recite that the challenge to confidentiality is being made in accordance with this
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specific paragraph of the Protective Order. The parties shall attempt to resolve each challenge in
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good faith and must begin the process by conferring directly (in voice to voice dialogue; other
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forms of communication are not sufficient) within 14 days of the date of service of notice. In
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conferring, the Challenging Party must explain the basis for its belief that the confidentiality
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designation was not proper and must give the Designating Party an opportunity to review the
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designated material, to reconsider the circumstances, and, if no change in designation is offered,
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to explain the basis for the chosen designation. A Challenging Party may proceed to the next
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stage of the challenge process only if it has engaged in this meet and confer process first or
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establishes that the Designating Party is unwilling to participate in the meet and confer process in
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a timely manner.
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6.3
Judicial Intervention. If the Parties cannot resolve a challenge without court
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intervention, the Designating Party shall file and serve a motion to retain confidentiality under
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Civil Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days
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of the initial notice of challenge or within 14 days of the parties agreeing that the meet and
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confer process will not resolve their dispute, whichever is earlier. Each such motion must be
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accompanied by a competent declaration affirming that the movant has complied with the meet
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and confer requirements imposed in the preceding paragraph. Failure by the Designating Party to
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make such a motion including the required declaration within 21 days (or 14 days, if applicable)
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shall automatically waive the confidentiality designation for each challenged designation. In
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addition, the Challenging Party may file a motion challenging a confidentiality designation at
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any time if there is good cause for doing so, including a challenge to the designation of a
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deposition transcript or any portions thereof. Any motion brought pursuant to this provision must
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be accompanied by a competent declaration affirming that the movant has complied with the
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180 Montgomery Street, Suite 1200
San Francisco, California 94104
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meet and confer requirements imposed by the preceding paragraph.
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The burden of persuasion in any such challenge proceeding shall be on the Designating
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Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
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unnecessary expenses and burdens on other parties) may expose the Challenging Party to
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sanctions. Unless the Designating Party has waived the confidentiality designation by failing to
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file a motion to retain confidentiality as described above, all parties shall continue to afford the
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material in question the level of protection to which it is entitled under the Producing Party’s
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designation until the court rules on the challenge.
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7.
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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is disclosed
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or produced by another Party or by a Non-Party in connection with this case only for
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prosecuting, defending, or attempting to settle this litigation. Such Protected Material may be
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disclosed only to the categories of persons and under the conditions described in this Order.
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When the litigation has been terminated, a Receiving Party must comply with the provisions of
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section 13 below (FINAL DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a location and
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in a 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 the court or permitted in writing by the Designating Party, a Receiving Party may
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disclose any information or item designated “CONFIDENTIAL” only to:
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(a) the Receiving Party’s Outside Counsel of Record in this action, as well as
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employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the
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information for this litigation and who have signed the “Acknowledgment and Agreement to Be
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Bound” that is attached hereto as Exhibit A;
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(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this litigation and who have
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signed the “Acknowledgment and 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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180 Montgomery Street, Suite 1200
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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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(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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(f) during their depositions, witnesses in the action to whom disclosure is reasonably
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necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
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A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
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transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
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separately bound by the court reporter and may not be disclosed to anyone except as permitted
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under this Stipulated Protective Order.
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(g) the author or recipient of a document containing the information or a custodian or
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other person who otherwise possessed or knew the information.
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
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LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation that compels
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disclosure of any information or items designated in this action as “CONFIDENTIAL,” that
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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
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the other litigation that some or all of the material covered by the subpoena or order is subject to
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this Protective Order. Such notification shall include a copy of this Stipulated Protective Order;
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and
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Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with the
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(c) cooperate with respect to all reasonable procedures sought to be pursued by the
subpoena or court order shall not produce any information designated in this action as
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“CONFIDENTIAL” before a determination by the court from which the subpoena or order
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issued, unless the Party has obtained the Designating Party’s permission. The Designating Party
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shall bear the burden and expense of seeking protection in that court of its confidential material –
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and nothing in these provisions should be construed as authorizing or encouraging a Receiving
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Party in this action to disobey a lawful directive from another court.
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9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
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LITIGATION
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(a) The terms of this Order are applicable to information produced by a Non-Party in this
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action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
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connection with this litigation is protected by the remedies and relief provided by this Order.
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Nothing in these provisions should be construed as prohibiting a Non-Party from seeking
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additional protections.
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(b) In the event that a Party is required, by a valid discovery request, to produce a Non-
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Party’s confidential information in its possession, and the Party is subject to an agreement with
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the Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
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(1) promptly notify in writing the Requesting Party and the Non-Party that some
or all of the information requested is subject to a confidentiality agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
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Order in this litigation, the relevant discovery request(s), and a reasonably specific description of
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the information requested; and
(3) make the information requested available for inspection by the Non-Party.
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(c) If the Non-Party fails to object or seek a protective order from this court within 14
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days of receiving the notice and accompanying information, the Receiving Party may produce
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the Non-Party’s confidential information responsive to the discovery request. If the Non-Party
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timely seeks a protective order, the Receiving Party shall not produce any information in its
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possession or control that is subject to the confidentiality agreement with the Non-Party before a
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determination by the court. Absent a court order to the contrary, the Non-Party shall bear the
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burden and expense of seeking protection in this court of its Protected Material.
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10.
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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
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Material to any person or in any circumstance not authorized under this Stipulated Protective
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Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the
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unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
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Protected Material, (c) inform the person or persons to whom unauthorized disclosures were
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made of all the terms of this Order, and (d) request such person or persons to execute the
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“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
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MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain inadvertently
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produced material is subject to a claim of privilege or other protection, the obligations of the
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Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This
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provision is not intended to modify whatever procedure may be established in an e-discovery
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order that provides for production without prior privilege review. Pursuant to Federal Rule of
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Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a
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communication or information covered by the attorney-client privilege or work product
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protection, the parties may incorporate their agreement in the stipulated protective order
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submitted to the court.
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12.
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MISCELLANEOUS
12.1
Right to Further Relief. Nothing in this Order abridges the right of any person to
seek its modification by the court in the future.
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12.2
Right to Assert Other Objections. By stipulating to the entry of this Protective
Order no Party waives any right it otherwise would have to object to disclosing or producing any
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information or item on any ground not addressed in this Stipulated Protective Order. Similarly,
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no Party waives any right to object on any ground to use in evidence of any of the material
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covered by this Protective Order.
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12.3
Filing Protected Material. Without written permission from the Designating Party
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or a court order secured after appropriate notice to all interested persons, a Party may not file in
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the public record in this action any Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be
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filed under seal pursuant to a court order authorizing the sealing of the specific Protected
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Material at issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a
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request establishing that the Protected Material at issue is privileged, protectable as a trade
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secret, or otherwise entitled to protection under the law. If a Receiving Party's request to file
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Protected Material under seal pursuant to Civil Local Rule 79-5(d) is denied by the court, then
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the Receiving Party may file the information in the public record pursuant to Civil Local Rule
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79-5(e) unless otherwise instructed by the court.
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13.
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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
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material. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
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compilations, summaries, and any other format reproducing or capturing any of the Protected
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Material. Whether the Protected Material is returned or destroyed, the Receiving Party must
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submit a written certification to the Producing Party (and, if not the same person or entity, to the
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Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all
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the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has
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not retained any copies, abstracts, compilations, summaries or any other format reproducing or
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capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to
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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
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legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work
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product, and consultant and expert work product, even if such materials contain Protected
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Material. Any such archival copies that contain or constitute Protected Material remain subject to
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this Protective Order as set forth in Section 4 (DURATION).
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Respectfully submitted,
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Dated: May 31, 2017
ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP
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By:
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/s/ Dale L. Allen, Jr.
DALE L. ALLEN, JR.
KEVIN P. ALLEN
PHILIP J. DOWNS, JR.
Attorneys for Defendants
CITY OF UNION CITY; UNION CITY
POLICE DEPARTMENT
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DATED: May 31, 2017
GERAGOS & GERAGOS
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By:
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/s/ David Gammill
DAVID GAMMILL
Attorneys for Plaintiffs
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: ________________________
5/31/17
___________________________________
UNITED STATES DISTRICT JUDGE
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [print or type full name], of _________________ [print or
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type full address], declare under penalty of perjury that I have read in its entirety and understand
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the Stipulated Protective Order that was issued by the United States District Court for the
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Northern District of California on [date] in the case of ___________ [insert formal name of the
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case and the number and initials assigned to it by the court]. I agree to comply with and to be
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bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that
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failure to so comply could expose me to sanctions and punishment in the nature of contempt. I
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solemnly promise that I will not disclose in any manner any information or item that is subject to
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this Stipulated Protective Order to any person or entity except in strict compliance with the
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provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District Court for the Northern
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District of California for the purpose of enforcing the terms of this Stipulated Protective Order,
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even if such enforcement proceedings occur after termination of this action.
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I hereby appoint __________________________ [print or type full name] of
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_______________________________________ [print or type full address and telephone
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number] as my California agent for service of process in connection with this action or any
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180 Montgomery Street, Suite 1200
San Francisco, California 94104
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
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proceedings related to enforcement of this Stipulated Protective Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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176111.1
STIPULATED PROTECTIVE ORDER
3:17-CV-01075-RS
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