Cleveland Constantine Browne v. Rodney Sebastian Clark Donalds

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION

12 Case No. 2:21-cv-02840-AB-AJR CLEVELAND CONSTANTINE

BROWNE, ET AL., [PROPOSED] STIPULATED

PROTECTIVE ORDER Plaintiffs, 15 v. RODNEY SEBASTIAN CLARK, an individual, ET AL.,

Defendants.

19 1. GENERAL 20 1. Purposes and Limitations. Discovery in this action is likely to involve 21 production of confidential, proprietary, or private information for which special 22 protection from public disclosure and from use for any purpose other than prosecuting 23 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 24 petition the Court to enter the following Stipulated Protective Order. The parties 25 acknowledge that this Order does not confer blanket protections on all disclosures or 26 responses to discovery and that the protection it affords from public disclosure and 27 use extends only to the limited information or items that are entitled to confidential 28 treatment under the…