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Church Mutual Insurance Co. v. Brotherhood Mutual Insurance Co.

United States District Court, C.D. California

June 8, 2017

CHURCH MUTUAL INSURANCE COMPANY, Plaintiff,
v.
BROTHERHOOD MUTUAL INSURANCE COMPANY; BROTHERHOOD MUTUAL INSURANCE SERVICES, LLC d.b.a. AMERICAN CHURCH INSURANCE AGENCY LLC; AMERICAN CHURCH GROUP LLC; AMERICAN CHURCH GROUP OF CALIFORNIA, LLC; THE CUTLER GROUP INC. d.b.a. CHURCHWEST INSURANCE SERVICES; JASON RAYMOND BARTENSTEIN, an individual; ZACAHARIAH DENTON FOLMER, an individual and ROBERT A. GAMMENTHALER, an individual, and DOES 1 to 10 Defendants.

          R. Bryan Martin Kristian Moriarty HAIGHT BROWN & BONESTEEL LLP Attorneys for Defendant AMERICAN CHURCH GROUP OF CALIFORNIA, LLC

          [PROPOSED] AMENDED CONFIDENTIALITY AND PROTECTIVE ORDER

          Hon. John F. Walter Judge

         This Court, having issued a Confidentiality and Protective Order on April 17, 2017, issues this Amended Confidentiality and Protective Order pursuant to the Amended Stipulation of the Parties filed on May 31, 2017:

         1. This Amended Protective Order regarding confidential, proprietary, and/or trade secret information applies in the above-captioned case to documents designated as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY.”

         2. Subject to the term and restrictions of this Amended Protective Order, the parties or otherwise interested persons may exchange confidential, trade secret, proprietary, or otherwise sensitive non-public documents or information. No provision in this Amended Protective Order shall be construed as requiring the disclosure of any documents or information.

         3. This Amended Protective Order applies to all documents and information produced by Plaintiff, Church Mutual Insurance Company (“Church Mutual”) or defendants, AMERICAN CHURCH GROUP, LLC, AMERICAN CHURCH GROUP OF CALIFORNIA, LLC, THE CUTLER GROUP, INC. dba CHURCH WEST INSURANCE SERVICES, JASON RAYMOND BARTENSTEIN, ZACARIAH DENTON FOLMER, and ROBERT A. GAMMENTHALER (“Defendants”), designated by the producing party as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY” in accordance with the terms of this Amended Protective Order.

         4. The parties may agree, in writing or on the record of any hearing, deposition or other proceeding in this matter, that additional documents, information, testimony, or materials may be brought within the provisions of this Amended Protective Order.

         5. Prior to producing documents or information, Church Mutual or Defendants shall mark as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY” any information, document, or portion of any document that contains trade secrets or other confidential technical proprietary, or financial information. In addition, as described in the provisions below, any other party has a right to challenge the propriety of a designation (or lack thereof) if it believes any designation was inappropriate, erroneous, or made in bad faith.

         6. The designation “CONFIDENTIAL” may be applied to information that Church Mutual or Defendants believes is proprietary, of a commercially sensitive nature, or which qualifies as a trade secret under California or Federal law. The designation “and/or “ATTORNEYS' EYES ONLY” may be applied to information if the designating party has a good-faith belief that the information discloses a party's trade-secret or highly confidential material, which is not publicly available and from which one or more of the parties could obtain an advantage, economic or otherwise, from the disclosure or use of that information.

         7. A confidentiality designation under this Amended Order shall be made by stamping or labeling each page containing Confidential Information as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY.”

         8. Church Mutual, Defendants, or its counsel may state on the record of any proceeding in which oral testimony is provided that specific testimony and the transcripts thereof are “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY.” Church Mutual, Defendants, or its counsel may also designate oral testimony as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY” by providing written notice to all receiving parties and the court reporter within fifteen days of receipt of any transcript of the specific pages and lines of the transcript that contains the protected information. The court reporter shall make appropriate notations of confidentiality on the pages of the transcript containing protected information in accordance with the designations supplied and additionally note on the cover of the transcript that it contains information subject to this Amended Protective Order.

         9. Accidental disclosure of protected information does not waive the confidentiality otherwise attached to the protected information.

         10. Any party to this case may challenge another party's designation of a document or information as protected under this Amended Order by delivering written notice to counsel identifying the document or information, and one or more bases for challenging the initial protected designation. If the dispute is not resolved consensually between the parties within seven (7) days of receipt of such notice of objection, the objecting party may move the Court for a ruling on the objection. The materials at issue must be treated as protected information, as designated by the designating party, until the Court has ruled on the objection or the matter has been otherwise resolved. Any motion challenging a designation pursuant to this paragraph will be made in compliance with United States District Court, Central District of California, Local Rules 37-1 and 37-2.

         11. No person who receives documents or information designated as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY” may disclose such to any other person, except as permitted by this Amended Protective Order, unless and until such designation is removed by the ...


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