April Davis v. The Kroger Company
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
APRIL DAVIS, MAHMOOD DAWOOD, and RHIANA Case No. 2:22-cv-02082-MEMF- CALKINS, RAO
Plaintiffs, [PROPOSED] STIPULATED v. PROTECTIVE ORDER1
THE KROGER COMPANY
DISCOVERY MATTER
Defendant.
17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve 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 24 discovery and that the protection it affords from public disclosure and use extends 25 26 27 only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 3 B. GOOD CAUSE…