Mill Creek Management and Real Estate Sales, Inc. v. United States Liability Insurance Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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11 MILL CREEK MANAGEMENT ) Case No. 1:24-cv-00984-KES-BAM 12 AND REAL ESTATE SALES, INC., ) ) 13 Plaintiff, ) [PROPOSED] PROTECTIVE ORDER 14 ) vs. ) 15 ) 16 UNITED STATES LIABILITY ) INSURANCE COMPANY, and 17 DOES 1 through 25, inclusive, ) ) 18 Defendants. ) ) 19

20 21 22 23 24 25 26 27 28 1 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public disclosure 5 and from use for any purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the Court to enter the 7 following Stipulated Protective Order. The parties acknowledge that this Order does 8 not confer blanket protections on all disclosures or responses to discovery and that 9 the protection it affords from public disclosure and use extends only to the limited 10 …