Board of Trustees of IBEW Local 100 Pension Trust Fund v. Trinity Construction Enterprises, Inc.

Charles P. Hamamjian, State Bar No. 298685

SAGASER, WATKINS & WIELAND, PC

5260 North Palm Avenue, Suite 400 Fresno, California 93704 Telephone: (559) 421-7000 Facsimile: (559) 473-1483 4 Attorneys for Defendant, TRINITY CONSTRUCTION ENTERPRISES INC dba TRINITY POWER 6 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

BOARD OF TRUSTEES OF IBEW LOCAL

100 PENSION TRUST FUND; BOARD OF Case No.: 1:23−CV−01048−KES−BAM

TRUSTEES OF JOINT ELECTRICAL

INDUSTRY TRAINING TRUST FUND; [PROPOSED] STIPULATED

BOARD OF TRUSTEES OF NECA/IBEW PROTECTIVE ORDER

FAMILY MEDICAL CARE TRUST FUND;

BOARD OF TRUSTEES OF NATIONAL

ELECTRICAL BENEFIT FUND, Plaintiff, vs. TRINITY CONSTRUCTION ENTERPRISES INC dba TRINITY POWER; and DOES 1 through 50, Defendants.

19 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…