Kelly Price v. Kawasaki Motors Corp USA
Filing
81
ORDER RE AGREED PROTECTIVE ORDER by Magistrate Judge Robert N. Block re Stipulation for Protective Order 78 . (See Order for details). (wr)
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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Gary A. Wolensky (#154041)
gwolensky@hewittwolensky.com
Elizabeth V. McNulty (#192455)
emcnulty@hewittwolensky.com
Cyrus D. Wilkes (#259625)
cwilkes@hewittwolensky.com
HEWITT WOLENSKY LLP
4041 MacArthur Blvd., Suite 300
Newport Beach, CA 92660
Telephone: (949) 783-5050
Facsimile: (949) 783-5059
Richard A. Mueller (Pro Hac Vice)
rmueller@thomsponcoburn.com
Carl J. Pesce (Pro Hac Vice)
cpesce@thompsoncoburn.com
Thompson Coburn LLP
One US Bank Plaza
St. Louis, MO 63101
Telephone: (314) 552-6000
Facsimile: (314) 552-7000
Attorneys for Defendant
Kawasaki Motors Corp., USA
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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KELLY PRICE, On Behalf of
Himself and All Others Similarly
Situated,
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Plaintiffs,
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vs.
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KAWASAKI MOTORS CORP.,
USA,
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Defendants.
CASE NO. SACV10-01074 JVS (RNBx)
ORDER RE
AGREED PROTECTIVE ORDER
BETWEEN PLAINTIFF AND
KAWASAKI MOTORS CORP., USA
CTRM:
MAGISTRATE:
JUDGE:
6D
Hon. Robert N. Block
Hon. James V. Selna
DATE OF FILING :
DISCOVERY CUT-OFF:
PRE-TRIAL DATE:
TRIAL DATE:
July 14, 2010
October 30, 2011
February 13, 2012
March 6, 2012
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AGREED PROTECTIVE ORDER
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This day come the parties, by agreement of all counsel, and represent the
following:
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WHEREAS, the parties hereto anticipate certain discovery requests seeking
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information which one or more of the parties consider to be proprietary,
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Confidential business records and/or trade secrets;
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WHEREAS, the parties have expressed a willingness to provide proprietary
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information, Confidential business records and/or trade secrets which would be
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produced in compliance with discovery requests, provided that the Court enters an
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appropriate Protective Order; and
IT IS, THEREFORE, HEREBY ORDERED AND ADJUDGED that all
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“Confidential” documents, as addressed further herein, and corresponding
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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information produced by a party in this matter in response to any other party’s
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requests for production of documents, interrogatories, request for admissions,
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deposition testimony or other requests for discovery in this case shall be subject to
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the terms of this Protective Order as set forth herein:
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1.
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faith, mark such materials or documents as it believes are entitled to protection, as
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“Confidential.” The documents, things, and information contained therein shall
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only be used, shown, and disclosed as provided in this Order. If such Confidential
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documents or information are produced in non-paper form or format, the
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designation of “Confidential” shall be marked on the media (diskette, CD, etc.) in
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which such documents or information are produced. To the extent that any medium
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shall have a “Confidential” designation upon it, the party receiving such medium
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shall similarly mark as “Confidential” any document or documents printed from
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such medium.
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2.
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term “Confidential Information” is defined to include such protectable information
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as may be contained in blueprints, manuals, test reports, test standards, drawings,
Protected Materials.
A party producing documents shall, in good
“Confidential Information” Defined: For purposes of this Order, the
AGREED PROTECTIVE ORDER
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correspondence, studies, marketing information, Engineering Change Orders,
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specifications, graphs, charts, financial data, or any other Confidential documents
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(and any deposition or other transcripts that include or reflect that information), that
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are produced by a party which has made a good faith determination regarding
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Confidentiality. Publicly available information is excluded from the scope of this
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order but, if the Plaintiff claims that anything marked by the Defendants as
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“Confidential” is “publicly available,” he shall first give notice to Defendants of
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that claim. The Producing Party bears the burden of proof at any hearing to
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determine whether the information has become “public.”
3.
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a document or documents as “Confidential” prior to production shall not be
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Newport Beach, California 92660
(949) 783-5050
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construed or interpreted as a waiver of protections provided under this Order. Upon
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discovery that the party has produced documents or other information containing
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“Confidential” information, the producing party shall provide written notice to
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counsel of record of its intention to mark such document or documents as
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“Confidential” and from the date of receipt of such notice, such materials and
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information shall be treated as “Confidential.”
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4.
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manner as to guard and protect the Confidential information and will endeavor to
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keep the number of copies made of such documents to a minimum.
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5.
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Qualified Persons.
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“Confidential” documents, the information contained therein, the contents or
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summaries thereof, or the existence thereof, to anyone other than as necessary to
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prosecute this specific litigation and only to: (a) Persons in the office of counsel, or
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co-counsel, of record for the parties; (b) Judicial Personnel. The Court, Court
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personnel and Court reporters in connection with this action; (c) Party or
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Designated Representatives who are employees or officers of any named party to
Failure to Mark Document as “Confidential.” The failure to mark
Information is to be protected.
Each party shall act in such a
Access to Confidential Documents and Information is limited to
The parties are prohibited from showing or disclosing
AGREED PROTECTIVE ORDER
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the litigation, provided that each such Party or designated representative executes,
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before receiving the disclosure, a copy of the Nondisclosure Agreement Concerning
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Information Covered by Protective Order (“Non Disclosure Agreement”) attached
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to this Protective Order as Exhibit A; and (d) Experts and consultants that have
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been actually retained in this litigation but only after they have signed the
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appropriate Nondisclosure Agreement acknowledging the existence of this Order
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and agreement to be bound thereby. The Nondisclosure Agreement will be retained
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by counsel for the party for whom it is executed. To the extent that experts or
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consultants are provided documents or information covered by this Order, they
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agree to execute the Nondisclosure Agreement attached hereto, including an oath
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that (a) they will only use the documents and information for the purposes of
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(949) 783-5050
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preparing or rendering expert advice or opinions to counsel of record in and for this
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case, (b) they submit themselves to the jurisdiction of this Court for any rulings
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regarding sanctions, contempt or other remedies necessitated by a violation of this
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order, ( c) they have read and understand the meaning and significance of the
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Protective Order, and (d) at the conclusion of the litigation they will return to
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Counsel that retained them the Protected Documents as well as any other
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documents that contain protected information. Those documents will immediately
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be returned to the producing party’s counsel as outlined below.
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Each person appropriately designated pursuant to this paragraph to receive
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Confidential information (with the exception of the Court and Court personnel),
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shall execute an Nondisclosure Agreement, in the form attached as Exhibit A.
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Opposing counsel shall be notified at least 10 days prior to disclosure to any such
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person who is known to be an current employee or agent of, or consultant to, any
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competitor of the party whose designated documents are sought to be disclosed.
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For purposes of this Order, the term ”competitor” shall be defined as any company,
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person or entity with a competitive interest that is adverse to Kawasaki (or the party
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producing the documents) or adverse to any company selling Kawasaki branded or
AGREED PROTECTIVE ORDER
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trade-marked goods, or other companies selling products (or after-market products)
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into such industries, including without limitation, any person (agent, lawyer,
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employee, dealer or contractor) to or from: Honda, Suzuki, BMW, Ducati, Yamaha,
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Harley Davidson, Polaris, Arctic, BRP, Bombardier, Triumph, Norton, Indian,
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BSA, Royal Enfield, Moto Guzzi, Aprilla, Victory. To the extent the Producing
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Party becomes aware of other competitors who make motorcycles, whose identities
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may not presently be known, the Producing Party will make these entities known to
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Plaintiff immediately and those entities will become part of this Order. Such notice
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shall provide a reasonable description of the outside independent person to whom
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disclosure is sought sufficient to permit objection to be made. If a party objects in
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writing to such disclosure within ten (10) days after receipt of notice, no disclosure
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Newport Beach, California 92660
(949) 783-5050
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shall be made until the party seeking disclosure obtains the prior approval of the
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Court or the objecting party.
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6.
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documents, or information contained therein, are not “Confidential” or otherwise
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entitled to protection under this Order, that party shall give notice of that claim to
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the party claiming such “Confidentiality.” The parties shall then attempt to resolve
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such dispute in good faith on an informal basis, and pursuant to Local Rules 37-1
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and 37-2, including the requirement that the parties file a Joint Stipulation
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concerning the matters in dispute. If the parties are unable to resolve their dispute
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informally, then the person challenging the designation (the "Challenging Party")
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may request appropriate relief from the Court.
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Designating Party to establish that the contested Protected Material is confidential.
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All such documents and information shall remain protected under this Order until
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they are released from that protection by an order of this Court.
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7.
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covered by this Order shall, at the conclusion of the litigation, if not previously
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contested and removed from the protections of this Order, remain protected and any
Challenges to Claims of Confidentiality. If any party claims that
It shall be the burden of the
Time for Contesting Confidentiality. Any documents or information
AGREED PROTECTIVE ORDER
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party or other person on their behalf is precluded from later challenging the
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Confidentiality of those documents or information.
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Order shall remain in effect after the conclusion of the litigation and all persons
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shown any materials covered by this Order shall be bound by the Order, unless
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otherwise agreed to by the parties to this Protective Order in writing.
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the “Confidential” documents or information agree, in advance, to submit
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themselves to the jurisdiction of this Court for a determination regarding their
This Order Remains in Effect. All provisions of this Protective
All Persons Subject to the Court’s Jurisdiction. All persons shown
compliance with the terms of the Order.
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10.
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(949) 783-5050
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matter to resolve any questions regarding the compliance with the terms of the
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Order.
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Confidential documents, things and information may be used solely in connection
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with this lawsuit and for no other purpose. No person who gains access to the
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Confidential documents, things and information may disclose them or their contents
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to any other person without the written stipulation of the producing party or by
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order of this Court. In no event shall such Confidential documents or information
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be provided to any person who is not “qualified” as set forth in Paragraph 5, above.
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Confidential documents, things and information shall be used solely for the
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purposes of this litigation and for no other purpose without further order of the
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Court. There shall be no reproduction whatsoever of “Confidential” documents,
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except as reasonably needed for the preparation of this case for trial.
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Confidential documents, things and information are used in depositions, all portions
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of the transcript of such depositions and exhibits thereto which refer to or relate to
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such Confidential documents, things or information shall themselves be considered
Jurisdiction of the Court: The Court retains jurisdiction over the
Use of Confidential Documents and Information Generally.
Use of Confidential Documents and Information in This Lawsuit.
If
AGREED PROTECTIVE ORDER
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as Confidential documents. The party introducing such Confidential documents,
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things and information shall instruct the court reporter to bind the Confidential
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portions of the transcript and exhibits separately and label them “Confidential.” In
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addition, each deponent is ordered that he may not divulge any Confidential
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documents, things or information except to qualified persons. No person shall
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attend portions of the depositions designated as Confidential unless he or she is an
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authorized recipient of documents containing such Confidential Information under
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the terms of this Order. The disclosing party or counsel for such party shall further
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have the right to exclude from any such deposition any person or persons not bound
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by the terms of this Protective Order during the duration of any deposition
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testimony relating to such Confidential documents, things or information.
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Newport Beach, California 92660
(949) 783-5050
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Following receipt of the transcript of a deposition portions of which were
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designated as Confidential, counsel for the designating party will identify, in
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writing to counsel of record, those specific portions of the transcript which are to be
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considered Confidential and subject to this Order. Any Party may so designate any
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portions of all depositions that logically relate to or are questions about documents
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that have been marked as Confidential, which will be treated as “designated” under
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the terms of this Order.
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papers to be filed with the Court contain information and/or documents that have
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been designated as “Confidential,” the proposed filing shall be accompanied by an
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application to file the papers or the portion thereof containing the designated
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information or documents (if such portion is segregable) under seal; and the
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application shall be directed to the judge to whom the papers are directed. For
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motions, the parties shall publicly file a redacted version of the motion and
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supporting papers.
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Filing and Sealing.
In accordance with Local Rule 79-5.1, if any
AGREED PROTECTIVE ORDER
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Actions: If any person receiving documents covered by this Order (“the Receiver”)
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is served with a subpoena, order, interrogatory, or document or civil investigative
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demand (collectively, a “Demand”) issued in any other action, investigation, or
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proceeding, and such Demand seeks Protected Material that was produced or
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designated as Confidential Information by someone other than the Receiver, the
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Receiver shall give prompt written notice by hand or facsimile transmission within
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(5) business days of receipt of such Demand to the person, party, or third party who
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produced or designated the materials as Confidential Information, and shall object
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to the production of such materials on the grounds of existence of this Order. The
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burden of opposing the enforcement of the Demand shall fall upon the party who
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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produced or designated the material as Confidential Information. Unless the person,
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party, or third party who produced or designated the Confidential Information
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obtains an order directing that the Demand not be complied with, and serves such
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order upon the Receiver prior to production pursuant to the Demand, the Receiver
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shall be permitted to produce documents responsive to the Demand on the Demand
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response date. Compliance by the Receiver with any order directing production
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pursuant to the Demand of any Confidential Information shall not constitute a
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violation of this Order. Nothing in this Order shall be construed as authorizing a
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party to disobey a lawful subpoena issued in another action.
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15.
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conclusion of this action by trial or otherwise, all Confidential documents, things
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and information and all copies (electronic or otherwise) thereof shall be returned to
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counsel for the producing party, excepting case pleadings and motions and
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correspondence of counsel provided that such counsel destroy all exhibits to such
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pleadings and correspondence that have been designated as Protected Material., No
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party or counsel for any party may retain an archival copy of any case pleading and
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motions and correspondence that has been designated as Protected Material under
Protected Material Subpoenaed or Ordered Produced in Other
Disposal at the Conclusion of this Action. Within 60 days of the
AGREED PROTECTIVE ORDER
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this Order. Additionally, all electronic copies of Confidential documents, things or
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information shall be certified by the receiving party as having been destroyed, and
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any media upon which such documents, things or information were produced shall
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be returned to the producing party. The conclusion of this litigation does not relieve
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the parties from their obligations to maintain Confidentiality obligations pursuant to
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this Order. The obligations imposed by this Protective Order shall survive the
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termination of this action.
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herein from seeking modification of this Order or to apply for additional or
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different protection. No modification by the parties shall have the force or effect of
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a Court order unless the Court approves the modification.
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(949) 783-5050
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17.
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the obligations pursuant thereto shall not be binding with respect to the producing
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party’s treatment of its own documents, things and information.
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18.
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“Confidential” documents or information only in writing, in the form of a stipulated
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order releasing the documents or information at issue from coverage under this
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Order. It will not be a defense to improper disclosure by a party (or anyone that
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was given access to the documents that are produced to a party) that the producing
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party or one of its attorneys orally approved disclosure.
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19.
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subject to a claim of attorney-client privilege, attorney work product or any valid
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ground under the law is nevertheless inadvertently or unintentionally produced,
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transmitted, or disclosed to a party or parties, such production, transmittal, or
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disclosure shall in no way prejudice or otherwise constitute a waiver of, or estoppel
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as to, any claim of privilege, work product or any valid ground under the law. If a
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disclosing party asserts a claim of inadvertent production, transmittal, or disclosure
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as to information then in the custody of another party, such receiving party shall,
Amendments. Nothing in this Order will prejudice any of the parties
Treatment of Producing Party’s Own Documents. This Order and
Procedure for Waiver.
A party may agree to the disclosure of
Unintentional Production of Privileged Materials. If information
AGREED PROTECTIVE ORDER
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within three (3) business days of being notified of such claim, return, or sequester
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the original and all copies of the information (except as necessary to file the motion
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with the Court referenced below) to the disclosing party and the receiving party
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shall not use such information for any purpose. If the receiving party has already
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shared such information or material prior to a demand for its return from the
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disclosing party, then the receiving party shall promptly notify the other affected
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person or persons and shall collect and return all copies. If the receiving party
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disputes a claim of attorney-client privilege, attorney work product or any valid
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ground under the law, it may move the Court for an Order compelling production of
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the material, which shall be filed under seal and which may attach the material for
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the Court’s inspection, but such motion shall not assert as a ground for entering
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Newport Beach, California 92660
(949) 783-5050
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such an Order the fact or circumstances of the inadvertent production, transmittal,
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or disclosure,
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or unintentional disclosure by any party of non-privileged material or information,
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regardless of whether the information was designated as Confidential at the time of
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disclosure, shall be remedied upon demand for its return by the producing or
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designating party. The recipient of such material shall return it, without retaining
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any copy of it, except as to file a motion as set forth below, promptly upon demand
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by the disclosing party (except as necessary to file the motion with the Court
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referenced below). If the receiving party has already shared such information or
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material prior to a demand for its return from the disclosing party, then the
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receiving party shall promptly notify the other affected person or persons and shall
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collect and return all copies. The receiving party may move the Court for an Order
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compelling production of the material, which motion shall be filed under seal and
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which may attach the material for the Court’s inspection, but such motion shall not
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assert as a ground for entering such an Order the fact or circumstances of the
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inadvertent production, transmittal, or disclosure.
Inadvertent Production of Non-Privileged Materials. Inadvertent
AGREED PROTECTIVE ORDER
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21.
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for employing reasonable measures to control, consistent with this Order,
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duplication of, access to, and distribution of copies of Confidential material.
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Parties shall not duplicate any Confidential material except as is necessary to
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prosecute the case and for filing in Court under seal. In the event of a violation of
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this Order, should the Court determine that counsel did not act responsibly in an
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effort to protect said information, such failure may be sanctionable.
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Responsibility of Attorneys. The attorneys of record are responsible
IT IS SO ORDERED.
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Dated: September 02, 2011
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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SEEN and AGREED:
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____________________________
Honorable Robert N. Block
United States Magistrate Judge.
HEWITT WOLENSKY LLP
By: /s/Elizabeth V. McNulty
_________________________
Gary A. Wolensky
Elizabeth V. McNulty
4041 MacArthur Blvd., Suite 300
Newport Beach, CA 92660
Telephone: (949) 783-5050
Facsimile: (949) 783-5059
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KREINDLER & KREINDLER LLP
By: /s/Natalie Finkelman Bennett
________________________
Gretchen M. Nelson
707 Wilshire Boulevard
Suite 4100
Los Angeles, CA 90017
Telephone: (213) 622-6449
Facsimile: (213) 622-6019
Richard A. Mueller
Carl J. Pesce (Pro Hac Vice)
Thompson Coburn, LLP
One US Bank Plaza
St. Louis, MO 63101
Telephone: (314) 552-6000
Facsimile: (314) 552-7000
James E. Miller
Karen Leser-Grenon
Shepherd, Finkelman, Miller &
Shah, LLP
65 Main Street
Chester, CT 06412
Telephone: (860) 526-1100
Facsimile: (860) 526-1120
Attorneys for Defendants,
KAWASAKI MOTORS CORP.,
USA
Natalie Finkelman
James C. Shah
Shepherd, Finkelman, Miller & Shah,
LLP
35 E. State Street
Media, PA 19063
(610) 891-9880
(610) 891-9883 Fax
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Attorneys for Plaintiff,
KELLY PRICE
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AGREED PROTECTIVE ORDER
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1
EXHIBIT A
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IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
SOUTHERN DIVISION
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KELLY PRICE, On
Behalf of Himself and All
Others Similarly Situated,
)
)
)
)
)
)
Plaintiff,
7
CIVIL ACTION NO. SACV10-01074
NON DISCLOSURE
AGREEMENT CONCERNING
INFORMATION COVERED BY
AGREED PROTECTIVE ORDER
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v.
)
)
)
)
)
)
)
)
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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KAWASAKI MOTORS
CORP., USA,
Defendant.
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NON DISCLOSURE AGREEMENT
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declares that :
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I reside at ____________________________________________ in the City of
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_______________________,
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_________________________.
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____________________________.
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County
of
____________________,
My
I am currently employed by
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of
number
is
,
located at
23
telephone
State
and my current job title is
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,
.
I have either read or have had the terms explained to me by my attorney and I
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understand the terms of the Protective order dated
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filed in Case No. SACV10-01074, Kelly Price v. Kawasaki Motors Corp., U.S.A.,
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pending in the United States District Court, Central District of California, Western
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Division. I agree to comply with and be bound by the provisions of the Protective
,
AGREED PROTECTIVE ORDER
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1
Order. I understand that any violation of the Protective Order may subject me to
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sanctions by the Court.
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I shall not divulge any documents (copies of any documents), information, or
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data designated “Confidential” obtained pursuant to such Protective order, or the
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contents of such documents or information, to any person other than those
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specifically authorized by the Protective Order.
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documents, information, or data except for the purposes of this action and pursuant
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to the terms of the Protective Order.
I shall not copy or use such
As soon as practical, but no later than 30 days after final termination of this
10
action, I shall return, to the attorney from whom I have received them, any
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documents, information, or data in my possession designated “Confidential,” and
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(949) 783-5050
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all copies, excerpts, summaries, notes, digests, abstracts, and indices relating to
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such documents, information, or data.
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I submit myself to the jurisdiction of the United States District Court, Central
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District of California, Western Division, for the purpose of enforcing or otherwise
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providing relief relating to the Protective Order.
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Dated:
By:
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(Signature)
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AGREED PROTECTIVE ORDER
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PROOF OF SERVICE
I am employed in the County of Orange, State of California. I am over the
age of 18 and not a party to the within action; my business address is 4041
MacArthur Blvd., Suite 300, Newport Beach, CA 92660.
On September ___, 2011, I served, in the manner indicated below, the
foregoing document described as AGREED PROTECTIVE ORDER on the
interested parties in this action by placing true copies thereof, enclosed in sealed
envelopes, at Newport Beach, addressed as follows:
Please see attached Service List
BY REGULAR MAIL: I caused such envelopes to be deposited in the
United States mail at Newport Beach, California, with postage thereon
fully prepaid. I am readily familiar with the firm’s practice of collection
and processing correspondence for mailing. It is deposited with the
United States Postal Service each day and that practice was followed in
the ordinary course of business for the service herein attested to
(F.R.C.P. 5(b)(2)(C).
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BY FACSIMILE: (F.R.C.P. 5(b)(2)(F)
BY FEDERAL EXPRESS: I caused such envelopes to be delivered by
air courier, with next day service, to the offices of the
addressees(F.R.C.P. 5(b)(2)(F).
BY ELECTRONIC SERVICE: I caused such document to be delivered
by electronic service as it has been authorized and agreed upon to service
electronically in this action to the parties below, to the email addresses
listed below. (F.R.C.P. 5(b)(2)(E)
I declare under penalty of perjury under the laws of the State of California
that the above is true and correct.
Executed on September ___, 2011, at Newport Beach, California.
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Andrea Greil
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PROOF OF SERVICE
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1
Service List
2
Price vs. Kawasaki – SA CV 10-01074 JVS
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Gretchen M. Nelson
Kreindler & Kreindler LLP
707 Wilshire Blvd., Suite 4100
Los Angeles, CA 90017
PLAINTIFF’S COUNSEL
James E. Miller
Karen Leser-Grenon
Shepherd, Finkelman, Miller & Shah, LLP
65 Main Street
Chester, CT 06412
PLAINTIFF’S COUNSEL
James C. Shah
Shepherd Finkelman, Miller & Shah, LLP
35 East State Street
Media, PA 19063
PLAINTIFF’S COUNSEL
Mark F. Anderson
Anderson, Ogilvie & Brewer
600 California Street, 18th Floor
San Francisco, CA 94108
PLAINTIFF’S COUNSEL
Rose Luzon
Shepherd Finkelman, Miller & Shah, LLP
401 West A Street, Suite 2350
San Diego, CA 92101
PLAINTIFF’S COUNSEL
213.622.6469
213.622.6019 fax
gnelson@kreindler.com
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860.526.1100
860.526.1120
mark@aoblawyers.com
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4041 MacArthur Blvd., Suite 300
Newport Beach, California 92660
(949) 783-5050
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610.891.9880
610.891.9883
jshah@sfmslaw.com
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415.651.1950
415.956.3233
mark@aoblawyers.com
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619.235.2416
619.234.7334
rluzon@sfmslaw.com
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PROOF OF SERVICE
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