Kristina Chiteishvili v. Vertifx LLC

• Court: District Court, C.D. California
• Decided: December 27, 2022
• Docket: 2:17-cv-08711
• Status: Unknown

Opinion

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| || ALEXANDRA KRAKOVSKY 2 || (State Bar No. 225527) 3 4653 Carmel Mountain Road, Suite 308 #239 San Diego, CA 92130 * || Telephone: (858) 705-9333 5 || E-mail: alexandra.krakovsky@gmail.com Attorney for Interested Party Motion Global Network Inc. 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 Kristina Chiteishvili Case No. 2:17-cv-08711-JFW-RAO 13 V. □ STIPULATED PROTECTIVE 14 Vertifx LLC ORDER! 15 16 17 | 1. A. PURPOSES AND LIMITATIONS 18 Post-judgment discovery in this action involves production of confidential, 19 || proprietary or private information for which special protection from public 20 || disclosure and from use for any purpose other than prosecuting this litigation may 21 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 22 || enter the following Stipulated Protective Order. The parties acknowledge that this 23 || Order does not confer blanket protections on all disclosures or responses to post- 24 || judgment discovery and that the protection it affords from public disclosure and use 25 || extends only to the limited information or items that are entitled to confidential 26 || treatment under the applicable legal principles. All of the document production 27 3g || | This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

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1 |] under this protective order is for attorneys’ eyes only, unless otherwise ordered by 2 || the Court. 4 B. GOOD CAUSE STATEMENT 5 Certain aspects of this post-judgment proceeding involve trade secrets, 6 || customer and pricing lists and other valuable research, development, commercial, 7 || financial, technical and/or proprietary information for which special protection from 8 || public disclosure and from use for any purpose other than prosecution of this action 9 || is warranted. Such confidential and proprietary materials and information consist 10 || of, among other things, confidential business or financial information, information 11 || regarding confidential business practices, or other confidential research, 12 || development, or commercial information (including information implicating privacy 13 |} rights of third parties), information otherwise generally unavailable to the public, or 14 || which may be privileged or otherwise protected from disclosure under state or 15 || federal statutes, court rules, case decisions, or common law. Accordingly, to 16 || expedite the flow of information, to facilitate the prompt resolution of disputes over 17 || confidentiality of discovery materials, to adequately protect information the parties 18 || are entitled to keep confidential, to ensure that the parties are permitted reasonable 19 || necessary uses of such material in preparation for and in the conduct of trial, to 20 || address their handling at the end of the litigation, and serve the ends of justice, a 21 || protective order for such information is justified in this matter. It is the intent of the 22 || parties that information will not be designated as confidential for tactical reasons 23 || and that nothing be so designated without a good faith belief that it has been 24 || maintained in a confidential, non-public manner, and there is good cause why it 25 || should not be part of the public record of this case. 26 || /// 27 || // 28 || ///

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l C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 2 The parties further acknowledge, as set forth in Section 12.3, below, that this 3 || Stipulated Protective Order does not entitle them to file confidential information 4 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 5 || and the standards that will be applied when a party seeks permission from the court 6 || to file material under seal. 7 There is a strong presumption that the public has a right of access to judicial 8 || proceedings and records in civil cases. In connection with non-dispositive motions, 9 || good cause must be shown to support a filing under seal. See Kamakana v. City and 10 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 11 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 12 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 13 || require good cause showing), and a specific showing of good cause or compelling 14 || reasons with proper evidentiary support and legal justification, must be made with 15 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 16 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 17 || without the submission of competent evidence by declaration, establishing that the 18 || material sought to be filed under seal qualifies as confidential, privileged, or 19 || otherwise protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 || compelling reasons, not only good cause, for the sealing must be shown, and the 22 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 23 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 24 || each item or type of information, document, or thing sought to be filed or introduced 25 || under seal in connection with a dispositive motion or trial, the party seeking 26 || protection must articulate compelling reasons, supported by specific facts and legal 27 || justification, for the requested sealing order. Again, competent evidence supporting 28 || the application to file documents under seal must be provided by declaration.

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I Any document that is not confidential, privileged, or otherwise protectable in 2 || its entirety will not be filed under seal if the confidential portions can be redacted. 3 || If documents can be redacted, then a redacted version for public viewing, omitting 4 || only the confidential, privileged, or otherwise protectable portions of the document 5 || shall be filed. Any application that seeks to file documents under seal in their 6 || entirety should include an explanation of why redaction is not feasible. 8 || 2. DEFINITIONS 9 2.1 Action: 2:17-cv-08711-JFW-RAO, Kristina Chiteishvili v. Vertifx LLC 10 2.2 Challenging Party: a Party or Non-Party that challenges the 11 |} designation of information or items under this Order. 12 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 13 || how it is generated, stored or maintained) or tangible things that qualify for 14 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 15 || the Good Cause Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 || their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 || items that it produces in disclosures or in responses to discovery as 20 || “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless 22 || of the medium or manner in which it is generated, stored, or maintained (including, 23 || among other things, testimony, transcripts, and tangible things) that are produced or 24 || generated in disclosures or responses to discovery in this matter, 2.7 Expert: a person with specialized knowledge or experience in a matter 26 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 27 || an expert witness or as a consultant in this Action. 28

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l 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 || House Counsel does not include Outside Counsel of Record or any other outside 3 || counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association or 5 || other legal entity not named as a Party to this action or not subject to post-judgment 6 || proceedings under California Code of Civil Procedure Sec. 708.010 et seq. All of 7 || the document production under this protective order is for attorneys’ eyes only, 8 || unless otherwise ordered by the Court. 9 2.10 Qutside Counsel of Record: attorneys who are not employees of a 10 || party to this Action but are retained to represent or advise a party to this Action and 11 || have appeared in this Action on behalf of that party or are affiliated with a law firm 12 || that has appeared on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 || employees, consultants, retained experts, and Outside Counsel of Record (and their 15 || support staffs) and any natural person, partnership, corporation, association or other 16 || legal entity subject to post-judgment proceedings under California Code of Civil 17 || Procedure Sec. 708.010 et seq. All of the document production under this protective 18 || order is for attorneys’ eyes only, unless otherwise ordered by the Court. 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 || Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing 23 exhibits or demonstrations, and organizing, storing, or retrieving data in any 24 form or medium) and their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 || designated as “CONFIDENTIAL” and falls within the following category: 27 14. ANY AND ALL WRITINGS AS DEFINED BY FEDERAL RULES OF 28 EVIDENCE, RULE 1001, INCLUDING ELECTRONICALLY STORED

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l INFORMATION, IN YOUR POSSESSION, CUSTODY OR CONTROL 2 EVIDENCING AGREEMENTS ENTERED INTO BETWEEN MOTION 3 GLOBAL NETWORK INC. AND ANY PERSON (WHETHER NATURAL 4 OR ARTIFICIAL) SINCE DECEMBER 7, 2010. > 6 2.15 Receiving Party: a Party that receives Disclosure or Discovery 7 || Material from a Producing Party. 9 |] 3. SCOPE 10 The protections conferred by this Stipulation and Order cover not only 11 || Protected Material (as defined above), but also (1) any information copied or 12 |] extracted from Protected Material; (2) all copies, excerpts, summaries, or 13 || compilations of Protected Material; and (3) any testimony, conversations, or 14 || presentations by Parties or their Counsel that might reveal Protected Material. 15 Any use of Protected Material at trial shall be governed by the orders of the 16 || trial judge. This Order does not govern the use of Protected Material at trial. 17 18 || 4. DURATION 19 Information that has been designated as CONFIDENTIAL or maintained 20 || pursuant to this protective order remains subject to this protective order and only 21 || becomes public (and, therefore, presumptively available to all members of the 22 || public, including the press) if it is used or introduced as an exhibit at trial or an 23 || evidentiary hearing and the trial judge does not find compelling reasons supported 24 || by specific factual findings to maintain its CONFIDENTIAL treatment. See 25 |} Kamakana, 447 F.3d at 1180-81 (distinguishing "good cause" showing for sealing 26 || documents produced in discovery from "compelling reasons" standard when merits- 27 || related documents are part of court record). The parties may petition the Court for a 28 || preliminary hearing in advance of any trial or evidentiary hearing on the issue of the

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1 || relevancy/materiality of any item in question for purposes of meeting the 2 || "compelling reasons" standard. 4 || 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 || Each Party or Non-Party that designates information or items for protection under 7 || this Order must take care to limit any such designation to specific material that 8 || qualifies under the appropriate standards. The Designating Party must designate for 9 || protection only those parts of material, documents, items or oral or written 10 communications that qualify so that other portions of the material, documents, items 11 || or communications for which protection is not warranted are not swept unjustifiably 12 || within the ambit of this Order. 13 Mass, indiscriminate or routinized designations are prohibited. Designations 14 || that are shown to be clearly unjustified or that have been made for an improper 15 || purpose (e.g., to unnecessarily encumber the case development process or to impose 16 || unnecessary expenses and burdens on other parties) may expose the Designating 17 || Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 || designated for protection do not qualify for protection, that Designating Party must 20 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 23 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 24 |/ under this Order must be clearly so designated before the material is disclosed or 25 || produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 || documents, but excluding transcripts of depositions or other pretrial or trial

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1 || proceedings), that the Producing Party affix at a minimum, the legend 2 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each page that 3 || contains protected material. If only a portion of the material on a page qualifies for 4 || protection, the Producing Party also must clearly identify the protected portion(s) 5 || (e.g., by making appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 || need not designate them for protection until after the inspecting Party has indicated 8 || which documents it would like copied and produced. During the inspection and 9 || before the designation, all of the material made available for inspection shall be 10 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 11 || documents it wants copied and produced, the Producing Party must determine which 12 || documents, or portions thereof, qualify for protection under this Order. Then, 13 || before producing the specified documents, the Producing Party must affix the 14 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 15 || portion of the material on a page qualifies for protection, the Producing Party also 16 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 17 || in the margins). 18 (b) for testimony given in depositions that the Designating Party identifies 19 || the Disclosure or Discovery Material on the record, before the close of the 20 || deposition all protected testimony. 21 (c) for information produced in some form other than documentary and 22 || for any other tangible items, that the Producing Party affix in a prominent place on 23 || the exterior of the container or containers in which the information is stored the 24 || legend “CONFIDENTIAL.” If only a portion or portions of the information 25 || warrants protection, the Producing Party, to the extent practicable, shall identify the 26 || protected portion(s). 7? 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 28 || failure to designate qualified information or items does not, standing alone, waive

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1 || the Designating Party’s right to secure protection under this Order for such material. 2 || Upon timely correction of a designation, the Receiving Party must make reasonable 3 || efforts to assure that the material is treated in accordance with the provisions of this 4 || Order. 6 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 || designation of confidentiality at any time that is consistent with the Court’s 9 || Scheduling Order. 10 6.2 Meetand Confer. The Challenging Party shall initiate the dispute 11 || resolution process under Local Rule 37.1 et seq. 12 6.3 The burden of persuasion in any such challenge proceeding shall be on 13 || the Designating Party. Frivolous challenges, and those made for an improper 14 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 15 || parties) may expose the Challenging Party to sanctions. Unless the Designating 16 || Party has waived or withdrawn the confidentiality designation, all parties shall 17 || continue to afford the material in question the level of protection to which it is 18 || entitled under the Producing Party’s designation until the Court rules on the 19 || challenge. 20 21 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1. Basic Principles. A Receiving Party may use Protected Material that is 23 || disclosed or produced by another Party or by a Non-Party in connection with this 24 || Action only for prosecuting, defending or attempting to settle this Action. Such 25 || Protected Material may be disclosed only to the categories of persons and under the 26 || conditions described in this Order. When the Action has been terminated, a 27 || Receiving Party must comply with the provisions of section 13 below (FINAL 28 || DISPOSITION).

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l Protected Material must be stored and maintained by a Receiving Party at a 2 || location and in a secure manner that ensures that access is limited to the persons 3 || authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 || otherwise ordered by the court or permitted in writing by the Designating Party, a 6 || Receiving Party may disclose any information or item designated 7 || “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 9 || well as employees of said Outside Counsel of Record to whom it is reasonably 10 || necessary to disclose the information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of 12 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 || disclosure is reasonably necessary for this Action and who have signed the 15 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 || Vendors to whom disclosure is reasonably necessary for this Action and who have 20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 || custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they 26 || will not be permitted to keep any confidential information unless they sign the 27 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 28 || agreed by the Designating Party or ordered by the court. Pages of transcribed 10

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1 || deposition testimony or exhibits to depositions that reveal Protected Material may 2 || be separately bound by the court reporter and may not be disclosed to anyone except 3 || as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 || mutually agreed upon by any of the parties engaged in settlement discussions. 7 II 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 8 IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 || that compels disclosure of any information or items designated in this Action as 11 || “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification 13 || shall include a copy of the subpoena or court order; 14 (b) promptly notify in writing the party who caused the subpoena or order 15 || to issue in the other litigation that some or all of the material covered by the 16 || subpoena or order is subject to this Protective Order. Such notification shall include 17 || a copy of this Stipulated Protective Order; and 18 (c) cooperate with respect to all reasonable procedures sought to be 19 || pursued by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely seeks a protective order, the Party served with 21 |} the subpoena or court order shall not produce any information designated in this 22 || action as “CONFIDENTIAL” before a determination by the court from which the 23 || subpoena or order issued, unless the Party has obtained the Designating Party’s 24 || permission. The Designating Party shall bear the burden and expense of seeking 25 || protection in that court of its confidential material and nothing in these provisions 26 || should be construed as authorizing or encouraging a Receiving Party in this Action 27 || to disobey a lawful directive from another court. 28 11

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1 |} 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a 4 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 5 || produced by Non-Parties in connection with this litigation is protected by the 6 || remedies and relief provided by this Order. Nothing in these provisions should be 7 || construed as prohibiting a Non-Party from seeking additional protections. All of the 8 || document production under this protective order is for attorneys’ eyes only, unless 9 || otherwise ordered by the Court. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 || produce a Non-Party’s confidential information in its possession, and the Party is 12 || subject to an agreement with the Non-Party not to produce the Non-Party’s 13 || confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 || that some or all of the information requested is subject to a confidentiality 16 || agreement with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 || specific description of the information requested; and 20 (3) make the information requested available for inspection by the 21 || Non-Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 23 || 14 days of receiving the notice and accompanying information, the Receiving Party 24 || may produce the Non-Party’s confidential information responsive to the discovery 25 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 26 || not produce any information in its possession or control that is subject to the 27 || confidentiality agreement with the Non-Party before a determination by the court. 28 || Absent a court order to the contrary, the Non-Party shall bear the burden and 12

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1 || expense of seeking protection in this court of its Protected Material. 3 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 || Protected Material to any person or in any circumstance not authorized under this 6 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 || persons to whom unauthorized disclosures were made of all the terms of this Order, 10 || and (d) request such person or persons to execute the “Acknowledgment and 11 || Agreement to Be Bound” that is attached hereto as Exhibit A. 12 13 |} 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 || inadvertently produced material is subject to a claim of privilege or other protection, 17 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 19 || procedure may be established in an e-discovery order that provides for production 20 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 21 || (e), insofar as the parties reach an agreement on the effect of disclosure of a 22 || communication or information covered by the attorney-client privilege or work 23 || product protection, the parties may incorporate their agreement in the stipulated 24 || protective order submitted to the court. 25 26 || 12. MISCELLANEOUS 27 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 28 || person to seek its modification by the Court in the future. 13

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l 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 || Protective Order, no Party waives any right it otherwise would have to object to 3 || disclosing or producing any information or item on any ground not addressed in this 4 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 || ground to use in evidence of any of the material covered by this Protective Order. 6 12.3. Filing Protected Material. A Party that seeks to file under seal any 7 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 8 || may only be filed under seal pursuant to a court order authorizing the sealing of the 9 || specific Protected Material at issue. If a Party’s request to file Protected Material 10 || under seal is denied by the court, then the Receiving Party may file the information 11 || in the public record unless otherwise instructed by the court. 12 13 || 13. VIOLATION 14 |) Any violation of this Order may be punished by appropriate measures including, 15 |} without limitation, contempt proceedings and/or monetary sanctions. 16 17 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 || Daten _ 42-26 - 2002 20 saad si i □ Attorneysfor Judgment Créditor 23 24 || DATED: _12-26.22 25 26 37 Attorneys for Third Person Examinee Motion Global Network Inc. 28 14

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1 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 DATED: _ 12/27/2022 4 .

|REEES 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 29 26 28 15

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l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that 7 || was issued by the United States District Court for the Central District of California 8 || on [date] in the case of 2:17-cv-08711-JFW-RAO, Kristina Chiteishvili v. Vertifx 9 || LLC I agree to comply with and to be bound by all the terms of this Stipulated 10 |} Protective Order and I understand and acknowledge that failure to so comply could 11 || expose me to sanctions and punishment in the nature of contempt. I solemnly 12 || promise that I will not disclose in any manner any information or item that is subject 13 || to this Stipulated Protective Order to any person or entity except in strict compliance 14 || with the provisions of this Order. 15 || I further agree to submit to the jurisdiction of the United States District Court for the 16 || Central District of California for enforcing the terms of this Stipulated Protective 17 || Order, even if such enforcement proceedings occur after termination of this action. 18 || [hereby appoint [print or type full name] of 19 [print or type full address and 20 || telephone number] as my California agent for service of process in connection with 21 || this action or any proceedings related to enforcement of this Stipulated Protective 22 |} Order. 23 || Date: 24 || City and State where sworn and signed: 25 26 || Printed name: 27 28 || Signature: 16