Bradford Aquatic Group, LLC v. Condor, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

BRADFORD AQUATIC GROUP, LLC Case No. 2:23-cv-09374-MEMF-AJR and BRADFORD PRODUCTS, LLC,

Plaintiffs, Hon. A. Joel Richlin

v. [PROPOSED] Stipulated Protective

Order CONDOR, INC. and DOUGLAS A.

HAVENS,

Defendants.

CONDOR, INC. and DOUGLAS A.

HAVENS

Counter-Plaintiffs

v.

BRADFORD AQUATIC GROUP, LLC,

BRADFORD PRODUCTS, LLC,

SHANE REPOLA, MICHAEL

BRODEUR, DALE BRODEUR, JR,

CINDY BRODEUR, & DOES 1-10,

Inclusive.

Counter-Defendants. 1. GENERAL 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…