Summary
This document is a stipulated protective order entered in Lighthouse Healthcare Center, LLC v. National Fire & Marine Insurance Company and MedPro Group, Inc. in the U.S. District Court for the Central District of California. It establishes procedures for designating, handling, challenging, disclosing, filing, and disposing of confidential discovery materials. The order was stipulated to by counsel and ordered by Magistrate Judge Maria A. Audero on September 15, 2025.
Topics
Practice areas
Questions Presented
- Whether good cause supported entry of a stipulated protective order governing confidential discovery materials.
- What procedures should govern designation, use, challenge, disclosure, sealing, and final disposition of protected discovery materials.
- Whether the protective order should preserve the parties' rights to seek additional protection, assert objections, and pursue sanctions or contempt for violations.
Holdings
- Good cause supported entry of a protective order limited to information and items entitled to confidential treatment under applicable legal principles.
- Material designated as confidential under the order, and information derived from it, may be used only to prosecute, defend, or attempt to settle the action and may be disclosed only to authorized categories of persons subject to the order's conditions.
- Confidentiality designations must be limited to specific qualifying material, made in good faith, and applied in the prescribed manner; a party challenging a designation must follow the meet-and-confer and applicable local procedures, while the designating party bears the burden of persuasion.
- Designation of discovery material as confidential does not itself authorize filing the material under seal; a party seeking sealing must comply with Local Rule 79-5 and make the showing required for the type of filing at issue, supported by competent evidence and narrowly tailored relief.
- When a producing party gives notice that inadvertently produced material is privileged or otherwise protected, the receiving parties must follow Federal Rule of Civil Procedure 26(b)(5)(B), subject to any applicable e-discovery procedures.
- After final disposition, protected material must be returned or destroyed upon timely written request, subject to specified archival-copy exceptions, and violations may be addressed through contempt proceedings, monetary sanctions, or other appropriate measures.
Key quotations
“The parties acknowledge that this Stipulated Protective 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.” (§ 1)
“The parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL does not—without the submission of competent evidence by declaration, establishing that the material sought to be filed under seal qualifies as confidential, privileged, or otherwise protectable—constitute good cause.” (§ 2)
“A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Nonparty in connection with this Action only for prosecuting, defending, or attempting to settle this Action.” (§ 8.1)
Factual background
The action is an insurance-contract dispute likely to involve confidential business, financial, pricing, underwriting, technical, proprietary, legal, and medical information. The parties sought procedures limiting use and disclosure of qualifying discovery materials, resolving confidentiality-designation disputes, protecting inadvertently produced privileged material, and handling protected material after final disposition. The court found that a protective order was justified to facilitate discovery and protect information entitled to confidential treatment.
Procedural history
Plaintiff filed the original complaint on February 26, 2025. During discovery, the parties anticipated exchanging confidential, proprietary, financial, commercial, legal, and medical information and jointly submitted a stipulated protective order. The court entered the order on September 15, 2025.