In re: Just for Men Mass Tort Litigation

Filing 48

ORDER - First Amended Stipulated Protective Order of Confidentiality. Signed by Judge David R. Herndon on 10/18/2018. (ceh)

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
______________________________________________________________________________
IN RE: Just For Men® Mass Tort Litigation
Case No. 3:16-cv-00638-DRH
Master Docket – In Re: Just For
Men® Mass Tort Litigation
______________________________________________________________________________
This Document Relates to:
ALL Just for Men® Cases
FIRST AMENDED
STIPULATED PROTECTIVE ORDER OF CONFIDENTIALITY
Pursuant to Rule 26 of the Federal Rules of Civil Procedure, the Court enters
the following Protective Order, which shall govern the designation and use of
Confidential Information (as defined herein) that may be produced or otherwise
disclosed during the course of this litigation by or on behalf of any party or nonparty. IT IS HEREBY ORDERED:
1.

Purpose.

The preparation for trial of this action may require the

discovery of certain documents and testimony that a defendant reasonably and in
good faith believes should be subject to a protective order under Rule 26 of the
Federal Rules of Civil Procedure or other state or federal law, including but not
limited to trade secrets, research, design, development, financial, technical,
marketing, planning, personal, proprietary, or commercial information.
1

Such

materials may include (a) documents containing product formulations for the
products manufactured, distributed, and/or sold by Defendants that are the
subject of this action; (b) documents and information made confidential pursuant
to statute, law, or regulation of any jurisdiction; (c) all other documents and
information

that

contain

trade

secrets,

research,

design,

development,

financial, technical, marketing, planning, personal, proprietary, or commercial
information

and

that

a

defendant

marks

as

“confidential”

or

“highly

confidential/outside attorneys’ eyes only”; and (d) all material, data, and
information obtained, derived, or generated from such materials.

Such

documents, testimony, and information are referred to below as “Confidential
Information.”
2.

Designation by Producing Defendant.
(a)

For purposes of this Order, the term “document” means all

written, recorded, or graphic material as described and defined in the
Federal Rules of Evidence and Federal Rules of Civil Procedure and shall
include

electronically

stored

information.

A

defendant

producing

documents or serving written discovery responses that such defendant
determines in good faith, after appropriate review by an attorney or by a
person working under the supervision of an attorney, contain Confidential
Information, shall designate such documents by placing a stamp or
marking on the documents stating the following: CONFIDENTIAL [or
2

HIGHLY CONFIDENTIAL/ATTORNEYS’ EYES ONLY].

Such markings

will not obscure, alter, or interfere with the legibility of the original
document.

Documents so marked are referred to in this Order as

“Protected Documents.”
(b)

A defendant may designate as “CONFIDENTIAL” those

documents and materials that constitute formulas, formulations, designs,
technical or non-technical data, devices, methods, techniques, drawings,
processes, research, development, manufacturing, financial data, pricing,
or proprietary commercial or business information that (i) are sufficiently
secret to derive economic value or economic advantage, actual or potential,
from not being generally known to other persons who can obtain
economic value from their disclosure or use, and (ii) are not generally
known and would not normally be disclosed to third parties (or, if
disclosed, would require such third parties to maintain the information on
a confidential basis), and are the subject of efforts that are reasonable
under the circumstances to maintain their secrecy or confidentiality.

A

defendant may also designate a document containing personal information
as “CONFIDENTIAL.”
(c)

A

defendant

CONFIDENTIAL/ATTORNEYS’

may
EYES

designate
ONLY”

those

as

“HIGHLY

materials

that

otherwise qualify as “CONFIDENTIAL,” and, in addition, are of such a
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sensitive, secret, or proprietary nature that the designating defendant
believes reasonably and in good faith that disclosure of the materials to
persons other than those identified in paragraph 5(g) of this Order would
create a material risk of serious injury to the designating defendant’s
commercial or business interests.
(d)

Portions of interrogatory answers, responses to requests for

admissions, deposition transcripts and exhibits, pleadings, motions,
affidavits, and briefs that quote, summarize, or contain Confidential
Information shall be Protected Documents, but, to the extent feasible, shall
be prepared in such a manner that the Confidential Information is bound
separately from that not entitled to protection; these portions that quote,
summarize, or contain materials entitled to protection will remain
Protected Documents regardless of labeling.
(e)

Confidential Information disclosed by a third party shall be

covered by this Order if a party notifies all other parties within thirty (30)
days of receipt of such information that the information or portions thereof
constitute or contain Confidential Information. Until the expiration of thirty
(30) days following receipt of such information, the information disclosed
by any such third party shall be treated as Confidential Information under
this Order.
(f)
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This order is not intended to provide protection to documents

produced in discovery beyond that which is allowed pursuant to FRCP
26(c)(1)(G) nor does this order confer a blanket protective order for all
documents produced.
3.

Depositions.

Protected Documents may be used or marked as

exhibits in depositions but shall remain subject to this Order.

If deposition

testimony discloses Confidential Information, counsel for the deponent or any
party shall inform the deposing counsel of the confidentiality of any such testimony
not later than twenty (20) days after receiving a copy of the deposition transcript or
by making the confidential designation as to the specific testimony in question on
the record at the deposition to be separately marked by the court reporter. Until
expiration of the 20-day period, the entire deposition will be treated as a Protected
Document under this Order.

If no party or deponent timely designates

Confidential Information in a deposition, then none of the transcript or its exhibits
shall be treated as confidential or highly confidential. If a designation is made, all
such testimony, each deposition transcript, recording, or portion thereof, and each
exhibit that is so designated, shall be treated as Confidential Information unless
otherwise agreed to by the parties or directed by order of the Court.
4.

5

Non-Disclosure of Confidential Information.

(a)

With the exception of persons and entities identified as

“Qualified Persons” in Paragraphs 5(g) and 5(h), Confidential Information
shall not be disclosed in any way to anyone for any purpose other than as
required for the preparation and trial of the above-captioned matter. Access
to and disclosure of Confidential Information shall be limited to those
persons designated as Qualified Persons below. All Qualified Persons given
access to Confidential Information shall keep all such information
confidential from all other persons except as specifically provided in this
Order.
(b)

To avoid security risks currently inherent in certain current

technologies and to facilitate compliance with the terms of this Order,
including, without limitation, the provisions of paragraphs 7(c), 9, and
10, and unless the party whose confidential information is at issue
agrees otherwise in writing, and except as set forth immediately below with
respect to limited electronic mail communications, all Qualified Persons
with access to Confidential Information (other than the persons and entities
identified as Qualified Persons in paragraphs 5(g) and 5(h)) shall be and are
prohibited from storing any Confidential Information in any online or
web-based storage location, when such storage location is managed or
maintained by any third-party service provider, including any provider of
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so-called “cloud computing” services, other than a reputable litigation
support service provider with a secure document hosting facility that
uses encrypted web-enabled software that allows for secure and protected
sharing and collaboration concerning said documents amongst only
authorized counsel and that does not employ so-called “cloud computing”
services. Notwithstanding the foregoing provision, a Qualified Person, as
defined in the following paragraph, shall not be prohibited from
transmitting to any other Qualified Person a reasonably limited number
of files containing Confidential Information through electronic mail, as
attachments to an electronic mail in the form of PDF files, as long as the
person transmitting the files takes reasonable steps to protect the
confidentiality of the files.
5.

Qualified Persons. Confidential Information may be disclosed only to

the following persons (hereinafter referred to as “Qualified Persons”):
(a)

Plaintiffs and Defendants (unless designated “attorneys eyes

only” or “outside attorneys’ eyes only” per paragraphs 5(g) below) and their
attorneys in the above-captioned matter.

Persons encompassed by the

preceding sentence include the attorneys’ employees (including outside copy
services, organizations involved in organizing, filing, coding, converting,
storing, or retrieving data or designing programs for handling data
connected with this action, including the performance of such duties in
7

relation to a computerized litigation support system, and stenographers);
(b)

Experts retained or consulted by a party for the purpose of

obtaining such expert’s advice or opinion regarding any issue in this
litigation, but only to the extent necessary for the expert to provide such
advice or opinion, except that disclosure shall not be made to any expert if
counsel for the party retaining that expert has actual knowledge that the
expert has been found to have violated the terms of a protective order in any
litigation or legal proceeding;
(c)

A deponent or a witness at deposition, trial or hearing, other

than those who are otherwise covered by paragraph 5(d), provided there is a
reasonable basis to believe that the witness will give relevant testimony
regarding the Confidential Information or that disclosure is necessary to
prepare the witness for the testimony.

If a party wishes to show

Confidential Information to such a deponent or witness before or during
a deposition, hearing, or trial, the deponent or witness must be informed
of this Protective Order and either sign a copy of the Non-Disclosure
Agreement attached hereto as Exhibit “A” or consent under oath to abide
by its provisions. This provision does not preclude the producing party
from objecting to or moving to preclude disclosure to any deponent or
witness, or to seek amendment of this provision in the future, if it
believes it has a good faith basis for such objection or motion;
8

(d)

A person identified in the document as a subject of the

communication, or having authored or previously received the document;
(e)

Any person mutually agreed upon among the parties;

(f)

The Court or any Court personnel, including any court

reporters;
(g)

Any

representatives,

insurance
claims

company

administrators,

(including
and

its

affiliates)

employees,

with

potential

obligations to any party, for purposes of evaluating potential liability or
insurance coverage in connection with this action, or in any future litigation
related to insurance coverage for this action, as well as any attorneys,
experts, or consultants retained by any insurance company in connection
with evaluating potential liability or insurance coverage for this action, or in
any future litigation related to insurance coverage for this action; and
(h)

The reinsurers, retrocessionaries, reinsurance intermediaries,

accountants, and outside or inside auditors of any insurance company
identified in paragraph 5(g), as well as any governmental, regulatory, or
administrative agency who may seek review of Confidential Information or
Protected Documents from any insurance company.
(i)
Confidential

Notwithstanding
Information

any
that

other
has

provisions
been

in

this

designated

Order,
HIGHLY

CONFIDENTIAL/ATTORNEYS’ EYES ONLY may be disclosed only to –
9

(1)

Outside counsel for the parties to this action, and their

employees, who are actively engaged in the conduct of this
lawsuit;
(2)

A witness at any deposition in this action who is an

employee of the producing party or who authored or was
copied on the document;
(3)

The Court and any employee thereof;

(4)

Experts retained or consulted by a party for the purpose

of obtaining such expert’s advice or opinion regarding any issue in
this litigation, but only to the extent necessary for the expert
to provide such advice or opinion, except that disclosure shall not
be made to any expert if: (a) the expert is a current employee of a
Competitor of Defendants, as that term is defined in Paragraph 6
below; or (b) counsel for the party retaining that expert has actual
knowledge that the expert has been found to have violated the
terms of a protective order in any litigation or legal proceeding;
and
(5)

The persons and entities identified in paragraphs 5(g)

and 5(h).
6.
10

Non-Disclosure to Competitors.

Notwithstanding the foregoing,

without express written consent, in no event shall any disclosure of Confidential
Information be made to any competitor of a Defendant producing party or to any
person who, upon reasonable and good faith inquiry, could be determined to be a
current employee of or consultant doing research for a competitor of a Defendant
producing party irrespective of whether such competitor or person is retained as an
expert in this action. “Competitor” shall mean any business entity engaged in the
research, development, manufacturing, or distribution of any product used to dye
or color hair or facial hair.
7.

Qualified Persons Bound by Order.
(a)

Before being given access to any Confidential Information, each

Qualified Person, other than the Court, the employees and staff of the
Court, counsel of record and the direct employees of counsel of record,
the persons and entities identified in paragraphs 5(g) and 5(h), and
witnesses who are shown Confidential Information at a deposition, trial
or hearing as set forth in paragraph 5(d), shall be advised of the terms of
this Order, shall be given a copy of this Order, shall agree in writing to be
bound by the terms of this Order by signing a copy of the Non-Disclosure
Agreement attached hereto as Exhibit “A,” and shall consent to the
exercise of personal jurisdiction by this Court in any proceeding(s) to
determine if the signatory violated this Order. Counsel for each party shall
maintain a list of all Qualified Persons to whom they or their client(s) have
11

provided any Confidential Information, which list shall be available for
inspection by the Court.
(b)

The witness who is a Qualified Person pursuant to paragraph

5(d) but who has not signed a copy of the Non-Disclosure Agreement
attached hereto as Exhibit “A” may be shown Confidential Information
before or during his or her testimony, but shall not be given a copy of the
documents containing such Confidential Information to keep. The witness
will review his or her transcribed testimony containing the Confidential
Information for purposes of completing the errata sheet within thirty (30)
days of receiving a copy of the deposition transcript from the court reporter
but may not keep any portion of the transcript that discusses the
Confidential Information. Once the witness has completed the errata sheet,
he or she must return to the court reporter the portions of the transcript
containing the Confidential Information, as well as any exhibits to that
portion of the transcript. Any documents used at the deposition that contain
Confidential Information (including marked exhibits) shall not be kept or
maintained by the witness or his or her counsel except that Qualified
Persons described in paragraph 5(b) may retain their depositions and
exhibits until the completion of the Qualified Person’s consultation or
representation in this case, at which time he or she shall follow the
procedures set forth in paragraph 7(c) below.
12

(c)

Any Confidential Information distributed or disclosed to a

Qualified Person who is a signatory of Exhibit “A” shall be returned to the
party’s counsel who provided it to the Qualified Person or, with the consent
of the party producing the Confidential Information, destroyed at the
completion of the Qualified Person’s consultation or representation in this
case.

Upon the request of the producing party or the Court, each such

Qualified Person shall execute an affidavit stating that all such documents
and copies thereof have been returned or destroyed as required. The
requirements of this paragraph shall not apply to the persons and entities
identified in paragraphs 5(g) and 5(h), who may retain Confidential
Information pursuant to their document retention policies.
(d)

The Court shall retain jurisdiction over any person or

organization authorized, as set forth above, to receive Confidential
Information as necessary to enforce the provisions of this Order.
8.

Challenges to Confidentiality Designation.

Nothing in this Order

shall constitute a waiver of any party’s right to object to the designation or nondesignation of a particular document, deposition transcript or discovery response
as a Protected Document.

A party can bring a challenge to any designated

document, deposition transcript or discovery response at any time.

If a party

contends that any material has been erroneously or improperly designated or not
designated as Confidential Information, the document at issue shall be treated as
13

confidential until (i) the parties reach a written agreement or (ii) this Court issues
an order stating that the material is not confidential and shall not be given
confidential treatment.
If a party in good faith wishes to challenge a disclosing party’s designation
of information or documents as confidential, or if a party in good faith desires to
provide Confidential Information to a Competitor, the party shall:
(a)

Notify the party that designated the information as Confidential

in writing (including via email) reasonably identifying the information (if
Protected Documents by identifying the production number of the documents
at issue);
(b)

The parties shall meet and confer in an effort to reach

agreement regarding the information at issue;
(c)

If, within fourteen (14) days of the objecting party’s notification

to the designating party, the parties cannot reach agreement on whether
some or all of the information should remain designated as confidential, the
party challenging the designation may move the Court for an order stating
that the information designated as “Confidential” is not “Confidential
Information” within the meaning of this Order and is not entitled to the
protections of this Order. If the objecting party does not file such a motion
within thirty (30) days after expiration of the 14-day period for negotiation
and the designating party has not agreed to extend the time for filing such a
14

motion, the information designated as “Confidential” shall be treated as
“Confidential Information” within the meaning of this Order, without waiver
by the objecting party to renew its objection in good faith and without
unreasonable delay at a future date, following the procedure set forth above.
With respect to any motions relating to the confidentiality of documents or
related information, the burden of justifying the designation shall lie with the
designating party. All parties retain the right to appeal the decision of the
Court.
9.

Authorized and Unauthorized Uses of Confidential Information.
(a)

Other than as set forth in paragraphs 5(g) and 5(h),

Confidential Information shall not be used for any business, competitive or
other non-litigation purpose without the express written consent of counsel
for the designating party, or by order of the Court.

Nothing in this

Protective Order shall limit any producing party’s use of its own documents
or shall prevent any producing party from disclosing its own Confidential
Information to any person.

Such disclosures shall not affect any

confidential designation made pursuant to the terms of this Protective
Order so long as the disclosure is made in a manner that is reasonably
calculated to maintain the confidentiality of the information. In the event of
future litigation related to insurance coverage for this action, any person or
entity identified in paragraphs 5(g) and 5(h) will not distribute, transmit, or
15

otherwise divulge any Confidential Information or Protected Documents
from this action unless and until a protective order providing similar
protection is requested in such litigation.
(b)

Use of Confidential Information in Court. If it is not feasible to

redact or exclude Confidential Information from a court filing, the parties
will use the following procedure, absent further Court Order, for submitting
to the Court papers consisting of, containing, or attaching Confidential
Information: Confidential Information is not to be filed with the Court
except when required in connection with motions or other matters pending
before the Court.

The party seeking to file Confidential Information in

support of a motion or other matter pending before the Court shall first
notify the producing party of its intent to file Confidential Information and
seek agreement to de-designate such information.

Absent a written

agreement to the contrary by the designating party, any Confidential
Information of any type filed in support of a motion or other matter pending
before the Court shall be filed under seal by first filing a motion with the
Court pursuant to the Local Rules and, upon an Order granting such
motion and consistent with the Local Rules, filing such Confidential
Information, together with the Order granting the motion to seal, in paper
form in an envelope delivered to the clerk of the Court and marked with the
title and caption of this action, the title of each document being filed, and a
16

statement substantially in the following form: “Pursuant to the Order of the
Court dated August 28, 2017, this envelope containing the above-entitled
documents filed by [the name of the party] is not to be opened nor the
contents thereof displayed or revealed, except by the Court, or in
accordance with an Order of the Court.” Portions of the court filing not
containing Confidential Information shall continue to be filed publicly with
the Court, and, wherever feasible, a redacted version of the court filing
excluding only Confidential Information shall be filed publicly with the
Court. Except as specifically provided in this Order, court filings will be
public.
(c)

Security of Confidential Information.

Except as specifically

provided in this Order, counsel shall keep all Confidential Information and
Protected Documents produced to them within their exclusive possession
and control, shall take all necessary and prudent measures to maintain the
confidentiality of such materials and information, and shall not permit
unauthorized dissemination of such materials to anyone.
10.
party,

Subpoena by Other Courts or Agencies.

tribunal,

quasi-judicial

agency,

or

If another court, third

administrative

agency

requests,

subpoenas, or orders production of Protected Documents or Confidential
Information from a party that has obtained those materials under the terms of this
Order, the party shall promptly notify the producing party of the pendency of such
17

subpoena or other process and shall not produce the Protected Documents or
Confidential Information until at least twenty-one (21) days after such notice,
unless ordered otherwise by a court of competent jurisdiction.

The

subpoenaed party will not oppose the producing party’s effort to intervene in
the proceeding, quash the subpoena, or take other reasonable action to seek
appropriate relief, with the cost of such opposition to the subpoena to be borne
by the producing party unless otherwise agreed to by the parties.
11.

Disposition of Confidential Information. After the final conclusion

of this action (including without limitation any appeals and after the time for filing
all appellate proceedings has passed), each party shall return all Confidential
Information to counsel for the party that produced it or destroy it (at the option of
the producing party), or otherwise shall comply with an applicable order of the
Court. The return or destruction of Confidential Information under this paragraph
shall include, without limitation, all copies, and duplicates thereof. The parties
shall certify, within thirty (30) days of final conclusion of the litigation that all
Confidential Information required to be returned or destroyed has been so returned
or destroyed.

Unless otherwise ordered by the Court, counsel may retain: (a)

copies of pleadings or other papers that have been filed with the Court and that
contain Confidential Information; (b) their work product; and (c) official transcripts
and exhibits thereto.

The terms and provisions of this Order shall continue to

apply to any such materials retained by counsel.
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The requirements of this

paragraph shall not apply to the persons and entities identified in paragraphs 5(g)
and 5(h), who may retain Confidential Information pursuant to their document
retention policies.
12.

Order Survives Termination of Action. After the termination of this

action by entry of a final judgment or order of dismissal, the provisions of this
Order shall continue to be binding. This Order is, and shall be deemed to be,
enforceable as to the parties, their agents, and their attorneys. The terms of this
Order may be enforced by filing a motion in this Court.
13.

Persons and Entities Bound by Order. This Order shall be binding

upon the parties, upon their attorneys, upon all signatories to Exhibit “A,” and
upon their successors, personal or legal representatives, subsidiaries, divisions,
employees, agents, and independent contractors.
14.

No Waiver of Objections.

Neither this Order nor any of the

procedures described above affects or constitutes a waiver of any party’s right to
object to the relevancy, admissibility or discoverability of any information or
document or to seek an order that discovery or admissibility be had only subject to
appropriate limits or restrictions, as provided by the Missouri Rules of Civil
Procedure, the Missouri Rules of Evidence, the Local Rules of this Court, or other
applicable rules or law.
15.

No Waiver of Privilege.
(a)

19

This Order does not affect or constitute a waiver of any

party’s right to withhold or redact information protected from disclosure
by the attorney-client privilege, physician-patient privilege, work product
doctrine, or other applicable privilege, protection, law, or regulation.
Furthermore, in discovery in this lawsuit, the parties do not intend to
disclose information subject to a claim of attorney-client privilege or
attorney work product protection.

If, nevertheless, a party (the

“Disclosing Party”) inadvertently discloses such privileged or work
product

information

(“Inadvertently

Disclosed

Information”),

such

disclosure shall not constitute or be deemed a waiver or forfeiture of any
claim of attorney-client privilege or work product immunity that the
Disclosing Party would otherwise be entitled to assert with respect to the
Inadvertently Disclosed Information and its subject matter. Consistent
with Federal Rule of Evidence 502(d), an inadvertent disclosure of a
privileged or protected item does not constitute a waiver for the purposes
of this action or other actions.
(b)

If

a

Disclosing

Party

notifies

the

receiving

party

of

Inadvertently Disclosed Information, or if the receiving party discovers
such an apparent inadvertent disclosure, the receiving party shall return
or destroy, within ten (10) days, all copies of such information and
provide a certification of counsel that all such Inadvertently Disclosed
Information has been returned or destroyed.
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From the moment a

receiving party discovers or is notified of inadvertent production, the
party shall not copy, distribute, or otherwise use in any manner the
disputed documents or information, and shall so instruct all persons to
whom the receiving party has disseminated a copy of the documents or
information.
16.

Inadvertent Production or Disclosure of Confidential Information.

In the event a party inadvertently produces Confidential Information without the
required legend, the producing party shall contact the receiving party within five
(5) days of the discovery of the inadvertent production, or as promptly as
reasonably possible thereafter, and inform the receiving party or parties in writing
of the inadvertent production and the specific material at issue. Such inadvertent
or unintentional disclosure shall not be deemed a waiver in whole or in part of the
producing party’s claim of confidentiality, either as to specific documents and
information disclosed or on the same or related subject matter. Upon receipt of
such notice, the receiving party or parties shall treat the material identified in the
notice as confidential unless (a) the parties agree to non-confidential treatment of
the subject material, or (b) the Court, on motion of any party, issues an order
addressing the appropriate treatment of the subject material. Each receiving party
shall further notify every person or organization that received copies of or access to
the material identified in the notice that such material contains Confidential
Information.
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17.

Modification Permitted.

Nothing in this Order shall prevent any

party or other person from seeking modification of this Order, or from objecting to
discovery that it believes to be otherwise improper.
18.

Use of Confidential Information at Trial. Nothing in this Order shall

preclude a party from introducing into evidence at trial or hearing any Confidential
Information or Protected Document that is admissible under the Federal Rules of
Evidence, nor shall anything in this Order be construed as sealing evidence
introduced at trial or hearing. At trial or evidentiary hearings, the Court may take
such measures, if it should deem it appropriate, to protect the claimed confidential
document or information sought to be admitted.
IT IS SO ORDERED.

Judge Herndon
2018.10.18
12:44:23 -05'00'
United States District Judge

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UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
EAST ST. LOUIS DIVISION
______________________________________________________________________________
IN RE: Just For Men Litigation
Case No. 3:16-cv-00638-DRH
Master Docket – In Re: Just For Men
Litigation
______________________________________________________________________________
This Document Relates to:
ALL Just for Men Cases
EXHIBIT A to PROTECTIVE ORDER

I,

, hereby acknowledge that I have

read the Protective Order of Confidentiality (“Protective Order”) entered in this
action and I understand the terms thereof. I agree to be bound by such terms,
and agree not to disclose any confidential or highly confidential information to any
person other than as permitted by the Protective Order. I hereby consent to the
exercise of personal jurisdiction by the above Court in any proceeding(s) to
enforce the terms of the Protective Order.

Signature

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Date