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

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

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

20 21 22 23 24 25 26 27 28 1. INTRODUCTION 1. PURPOSES AND LIMITATIONS 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 10 …