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Cahilig v. Ikea U.S. Retail, LLC

United States District Court, C.D. California

July 8, 2019

ALLYZA CAHILIG, on behalf of herself and all others similarly situated, Plaintiff,
IKEA U.S. RETAIL, LLC, a Virginia limited liability company; and DOES 1 through 100, inclusive, Defendant.


          LAW OFFICES OF KEVIN T. BARNES Kevin T. Barnes, Esq., Gregg Lander, Esq. Attorneys for Plaintiff


          Honorable Alka Sagar, United States Magistrate Judge.


         Defendant asserts that discovery in this action is 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 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.


         Good cause exists for the entry of this Stipulated Protective Order as follows:

         (a) In this action, plaintiff Allyza Cahilig (“Plaintiff”) asserts the following causes of action against defendant IKEA U.S. Retail, LLC (“Defendant”) on behalf of herself and all current and former non-exempt employees in California during the period January 10, 2015, through the present: (1) Failure to Provide All Paid Rest Periods; (2) Violations of Labor Code § 203; (3) Derivative Failure to Timely Furnish Accurate Itemized Wage Statements; (4) Independent Failure to Timely Furnish Accurate Itemized Wage Statements; (5) Penalties Pursuant to Labor Code § 2699; and (6) Unfair Business Practices.

         (b) Based on the nature of this case, the allegations asserted by Plaintiff, and the discovery requests anticipated in this action, Defendant anticipates that documents, materials, and other information to be exchanged in discovery may reveal private, confidential for the putative class members, and may reveal private, confidential and/or proprietary information of Defendant's business policies and practices. Such materials, to the extent they are discoverable in this action, could reveal confidential information concerning: putative class members' financial information, putative class members' contact information, putative class members' personnel information, Defendant's employment practices, Defendant's business operations, Defendant's finances, Defendant's clients, Defendant's employees, and information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or common law.

         (c) Due to the nature of the information described herein, putative class members' interests in their privacy and Defendant's business interests may suffer harm if such information is disclosed publicly. Potential harm that may result from the public disclosure of such information may include, but is not limited to, loss of privacy, economic losses, loss of competitive advantages, and diminution of goodwill. Accordingly, to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of the litigation, and serve the ends of justice, Defendant asserts that a protective order for such information is justified in this matter. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case.

         2. DEFINITIONS

         2.1 Action: this pending federal lawsuit entitled Cahilig v. IKEA Retail U.S., LLC, No. 2:19-cv-01182-CJC (ASx).

         2.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         2.3 “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), and as specified above in the Good Cause Statement.

         2.4 Counsel: Outside Counsel of Record and In-House Counsel (as well as their support staff).

         2.5 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

         2.6 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.

         2.7 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.

         2.8 In-House Counsel: attorneys who are employees of a party to this Action. In-House Counsel does not include Outside Counsel of Record or any other outside counsel.

         2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this Action.

         2.10 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, and includes support staff.

         2.11 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).

         2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action.

         2.13 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.

         2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.”

         2.15 Receiving Party: a Party that receives Disclosure or Discovery ...

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