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4840-5947-7581.2 1 Case No. 3:17-cv-00855-WHA (JSC)

NON-DISCLOSURE AGREEMENT FOR STIPULATED PROTECTIVE ORDER

John M. Cowden (State Bar No. 224963) 

 jmc@manningllp.com 

Jordon Ferguson (State Bar No. 276578) 

 jrf@manningllp.com

MANNING & KASS 

ELLROD, RAMIREZ, TRESTER LLP 

19800 MacArthur Blvd, Suite 900 

Irvine, California 92612 

Telephone: (949) 440-6690 

Facsimile: (949) 474-6991 

Attorneys for Defendant, 

THE PROPERTY SCIENCES GROUP, INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 

CANDIDA PALEGA, on behalf of herself and 

on behalf of all others similarly situated,

Plaintiff,

v.

THE PROPERTY SCIENCES GROUP, 

INCORPORATED,

Defendant.

Case No. 3:17-cv-00855-WHA (JSC)

The Hon. William H. Alsup

[PROPOSED] STIPULATED PROTECTIVE 

ORDER

Action Filed: February 21, 2017

Trial Date: October 15, 2018

 WHEREAS the parties in the action pending in the United States District Court for the 

Northern District of California, San Francisco Division, entitled Candida Palega, et al. v. The 

Property Sciences Group, Inc., Case No. 3:17-cv-00855-WHA (JSC) ("the Litigation"), Defendant 

The Property Sciences Group, Inc., and Plaintiff Candida Palega (herein collectively referred to as 

"The Parties"), by their counsel and subject to the approval of the Court, have entered into a 

Stipulation for Protective Order re: Confidential Information ("Protective Order"), and good cause 

appearing therefore, the court HEREBY ORDERS AS FOLLOWS:

1. PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are likely to involve production of confidential, 

proprietary, or private information for which special protection from public disclosure and from use 

for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties 
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4840-5947-7581.2 2 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The 

parties acknowledge that this Order does not confer blanket protections on all disclosures or responses 

to discovery and that the protection it affords from public disclosure and use extends only to the 

limited information or items that are entitled to confidential treatment under the applicable legal 

principles. The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 

Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-

5 sets forth the procedures that must be followed and the standards that will be applied when a party 

seeks permission from the court to file material under seal. 

2. DEFINITIONS 

 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information 

or items under this Order. 

2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is 

generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 

Civil Procedure 26(c). 

2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as 

their support staff). 

2.4 Designating Party: a Party or Non-Party that designates information or items that it 

produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 

2.5 Disclosure or Discovery Material: all items or information, regardless of the medium 

or manner in which it is generated, stored, or maintained (including, among other things, testimony, 

transcripts, and tangible things), that are produced or generated in disclosures or responses to 

discovery in this matter. 

2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the 

litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 

consultant in this action. 

2.7 House Counsel: attorneys who are employees of a party to this action. House Counsel 

does not include Outside Counsel of Record or any other outside counsel. 

2.8 Non-Party: any natural person, partnership, corporation, association, or other legal 
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4840-5947-7581.2 3 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

entity not named as a Party to this action. 

2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action 

but are retained to represent or advise a party to this action and have appeared in this action on behalf 

of that party or are affiliated with a law firm which has appeared on behalf of that party. 

2.10 Party: any party to this action, including all of its officers, directors, employees, 

consultants, retained experts, and Outside Counsel of Record (and their support staffs). 

2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material 

in this action. 

2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., 

photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, 

or retrieving data in any form or medium) and their employees and subcontractors. 

2.13 Protected Material: any Disclosure or Discovery Material that is designated as 

“CONFIDENTIAL.” 

2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a 

Producing Party. 

3. SCOPE 

The protections conferred by this Stipulation and Order cover not only Protected Material (as 

defined above), but also (1) any information copied or extracted from Protected Material; (2) all 

copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 

conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 

However, the protections conferred by this Stipulation and Order do not cover the following 

information: (a) any information that is in the public domain at the time of disclosure to a Receiving 

Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 

publication not involving a violation of this Order, including becoming part of the public record 

through trial or otherwise; and (b) any information known to the Receiving Party prior to the 

disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 

information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 

Protected Material at trial shall be governed by a separate agreement or order. 
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4840-5947-7581.2 4 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

4. DURATION 

Even after final disposition of this litigation, the confidentiality obligations imposed by this 

Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 

otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 

defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 

and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time 

limits for filing any motions or applications for extension of time pursuant to applicable law. 

5. DESIGNATING PROTECTED MATERIAL 

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 

Non-Party that designates information or items for protection under this Order must take care to limit 

any such designation to specific material that qualifies under the appropriate standards. The 

Designating Party must designate for protection only those parts of material, documents, items, or oral 

or written communications that qualify – so that other portions of the material, documents, items, or 

communications for which protection is not warranted are not swept unjustifiably within the ambit of 

this Order. 

Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to 

be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber 

or retard the case development process or to impose unnecessary expenses and burdens on other 

parties) expose the Designating Party to sanctions. 

If it comes to a Designating Party’s attention that information or items that it designated for protection 

do not qualify for protection, that Designating Party must promptly notify all other Parties that it is 

withdrawing the mistaken designation. 

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, 

e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 

Discovery Material that qualifies for protection under this Order must be clearly so designated before 

the material is disclosed or produced. 

Designation in conformity with this Order requires: 

(a) for information in documentary form (e.g., paper or electronic documents, but 
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4840-5947-7581.2 5 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 

affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion or 

portions of the material on a page qualifies for protection, the Producing Party also must clearly 

identify the protected portion(s) (e.g., by making appropriate markings in the margins). 

 A Party or Non-Party that makes original documents or materials available for inspection need 

not designate them for protection until after the inspecting Party has indicated which material it would 

like copied and produced. During the inspection and before the designation, all of the material made 

available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified 

the documents it wants copied and produced, the Producing Party must determine which documents, 

or portions thereof, qualify for protection under this Order. Then, before producing the specified 

documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page that contains 

Protected Material. If only a portion or portions of the material on a page qualifies for protection, the 

Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate 

markings in the margins). 

(b) for testimony given in deposition or in other pretrial or trial proceedings, that the 

Designating Party identify on the record, before the close of the deposition, hearing, or other 

proceeding, all protected testimony. 

(c) for information produced in some form other than documentary and for any other 

tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 

containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a portion 

or portions of the information or item warrant protection, the Producing Party, to the extent 

practicable, shall identify the protected portion(s). 

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 

designate qualified information or items does not, standing alone, waive the Designating Party’s right 

to secure protection under this Order for such material. Upon timely correction of a designation, the 

Receiving Party must make reasonable efforts to assure that the material is treated in accordance with 

the provisions of this Order. 

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 
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4840-5947-7581.2 6 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 

confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 

designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 

or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 

confidentiality designation by electing not to mount a challenge promptly after the original 

designation is disclosed. 

6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by 

providing written notice of each designation it is challenging and describing the basis for each 

challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must recite 

that the challenge to confidentiality is being made in accordance with this specific paragraph of the 

Protective Order. The parties shall attempt to resolve each challenge in good faith and must begin the 

process by conferring directly (in voice to voice dialogue; other forms of communication are not 

sufficient) within 14 days of the date of service of notice. In conferring, the Challenging Party must 

explain the basis for its belief that the confidentiality designation was not proper and must give the 

Designating Party an opportunity to review the designated material, to reconsider the circumstances, 

and, if no change in designation is offered, to explain the basis for the chosen designation. A 

Challenging Party may proceed to the next stage of the challenge process only if it has engaged in this 

meet and confer process first or establishes that the Designating Party is unwilling to participate in the 

meet and confer process in a timely manner. 

6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court 

intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil 

Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days of the 

initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process 

will not resolve their dispute, whichever is earlier. Each such motion must be accompanied by a 

competent declaration affirming that the movant has complied with the meet and confer requirements 

imposed in the preceding paragraph. Failure by the Designating Party to make such a motion 

including the required declaration within 21 days (or 14 days, if applicable) shall automatically waive 

the confidentiality designation for each challenged designation. In addition, the Challenging Party 
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4840-5947-7581.2 7 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

may file a motion challenging a confidentiality designation at any time if there is good cause for doing 

so, including a challenge to the designation of a deposition transcript or any portions thereof. Any 

motion brought pursuant to this provision must be accompanied by a competent declaration affirming 

that the movant has complied with the meet and confer requirements imposed by the preceding 

paragraph. 

The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 

Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 

expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 

Designating Party has waived the confidentiality designation by failing to file a motion to retain 

confidentiality as described above, all parties shall continue to afford the material in question the level 

of protection to which it is entitled under the Producing Party’s designation until the court rules on the 

challenge. 

7. ACCESS TO AND USE OF PROTECTED MATERIAL 

7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 

produced by another Party or by a Non-Party in connection with this case only for prosecuting, 

defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to the 

categories of persons and under the conditions described in this Order. When the litigation has been 

terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 

DISPOSITION). 

Protected Material must be stored and maintained by a Receiving Party at a location and in a 

secure manner that ensures that access is limited to the persons authorized under this Order. 

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by 

the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 

information or item designated “CONFIDENTIAL” only to:

(a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 

of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for 

this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is 

attached hereto as Exhibit A; 
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4840-5947-7581.2 8 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

(b) the officers, directors, and employees (including House Counsel) of the Receiving 

Party to whom disclosure is reasonably necessary for this litigation and who have signed the 

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 

reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to 

Be Bound” (Exhibit A);

(d) the court and its personnel; 

(e) court reporters and their staff, professional jury or trial consultants, mock jurors, and 

Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

(f) during their depositions, witnesses in the action to whom disclosure is reasonably 

necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 

unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed 

deposition testimony or exhibits to depositions that reveal Protected Material must be separately 

bound by the court reporter and may not be disclosed to anyone except as permitted under this 

Stipulated Protective Order. 

(g) the author or recipient of a document containing the information or a custodian or 

other person who otherwise possessed or knew the information. 

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 

LITIGATION 

If a Party is served with a subpoena or a court order issued in other litigation that compels 

disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party 

must: 

(a) promptly notify in writing the Designating Party. Such notification shall include a copy 

of the subpoena or court order; 

(b) promptly notify in writing the party who caused the subpoena or order to issue in the 

other litigation that some or all of the material covered by the subpoena or order is subject to this 

Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 
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4840-5947-7581.2 9 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

(c) cooperate with respect to all reasonable procedures sought to be pursued by the 

Designating Party whose Protected Material may be affected. 

If the Designating Party timely seeks a protective order, the Party served with the subpoena or 

court order shall not produce any information designated in this action as “CONFIDENTIAL” before 

a determination by the court from which the subpoena or order issued, unless the Party has obtained 

the Designating Party’s permission. The Designating Party shall bear the burden and expense of 

seeking protection in that court of its confidential material – and nothing in these provisions should be 

construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful directive 

from another court. 

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS 

LITIGATION 

(a) The terms of this Order are applicable to information produced by a Non-Party in this 

action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 

connection with this litigation is protected by the remedies and relief provided by this Order. Nothing 

in these provisions should be construed as prohibiting a Non-Party from seeking additional 

protections. 

(b) In the event that a Party is required, by a valid discovery request, to produce a NonParty’s confidential information in its possession, and the Party is subject to an agreement with the 

Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 

(1) promptly notify in writing the Requesting Party and the Non-Party that some or all 

of the information requested is subject to a confidentiality agreement with a Non-Party; 

(2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in 

this litigation, the relevant discovery request(s), and a reasonably specific description of the 

information requested; and 

(3) make the information requested available for inspection by the Non-Party. 

(c) If the Non-Party fails to object or seek a protective order from this court within 14 days 

of receiving the notice and accompanying information, the Receiving Party may produce the NonParty’s confidential information responsive to the discovery request. If the Non-Party timely seeks a 
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4840-5947-7581.2 10 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

protective order, the Receiving Party shall not produce any information in its possession or control 

that is subject to the confidentiality agreement with the Non-Party before a determination by the court. 

Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking 

protection in this court of its Protected Material. 

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 

Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 

the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 

disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 

inform the person or persons to whom unauthorized disclosures were made of all the terms of this 

Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be 

Bound” that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 

MATERIAL 

When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 

material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 

are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 

modify whatever procedure may be established in an e-discovery order that provides for production 

without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 

parties reach an agreement on the effect of disclosure of a communication or information covered by 

the attorney-client privilege or work product protection, the parties may incorporate their agreement in 

the stipulated protective order submitted to the court. 

12. MISCELLANEOUS 

12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek 

its modification by the court in the future. 

12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no 

Party waives any right it otherwise would have to object to disclosing or producing any information or 

item on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any 
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4840-5947-7581.2 11 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

right to object on any ground to use in evidence of any of the material covered by this Protective 

Order. 

12.3 Filing Protected Material. Without written permission from the Designating Party or a 

court order secured after appropriate notice to all interested persons, a Party may not file in the public 

record in this action any Protected Material. A Party that seeks to file under seal any Protected 

Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 

pursuant to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to 

Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that the Protected 

Material at issue is privileged, protectable as a trade secret, or otherwise entitled to protection under 

the law. If a Receiving Party's request to file Protected Material under seal pursuant to Civil Local 

Rule 79-5(d) is denied by the court, then the Receiving Party may file the information in the public 

record pursuant to Civil Local Rule 79-5(e) unless otherwise instructed by the court. 

13. FINAL DISPOSITION 

Within 60 days after the final disposition of this action, as defined in paragraph 4, each 

Receiving Party must return all Protected Material to the Producing Party or destroy such material. As 

used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 

summaries, and any other format reproducing or capturing any of the Protected Material. Whether the 

Protected Material is returned or destroyed, the Receiving Party must submit a written certification to 

the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day 

deadline that (1) identifies (by category, where appropriate) all the Protected Material that was 

returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, 

compilations, summaries or any other format reproducing or capturing any of the Protected Material. 

Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 

papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and 

trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if 

such materials contain Protected Material. Any such archival copies that contain or constitute 

Protected Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 
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4840-5947-7581.2 12 Case No. 3:17-cv-00855-WHA (JSC)

[PROPOSED] STIPULATED PROTECTIVE ORDER

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

DATED: August 24, 2017

KENNEDY HODGES, LLP

By: /s/ William Hogg

Galvin B. Kennedy

William Hogg

Attorneys for Plaintiff,

CANDIDA PALEGA

DATED: August 24, 2017

CAFFARELLI & ASSOCIATES LTD

By: /s/ Lorrie T. Peeters

Lorrie T. Peeters

Attorneys for Plaintiff,

CANDIDA PALEGA

DATED: August 24, 2017

MANNING & KASS

ELLROD, RAMIREZ, TRESTER LLP

By: /s/ Jordon R. Ferguson

John M. Cowden

Jordon R. Ferguson

Attorneys for Defendant,

THE PROPERTY SCIENCES GROUP, INC.

PURSUANT TO STIPULATION, IT IS SO ORDERED 

Dated: _________________ 2017 _____________________________ 

 Hon. Jacqueline Scott Corley 

United States Magistrate Judge 

August 28, .

William Alsup