Jon Anthony Clark v. Freedom Forever LLC

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

9 10 JON ANTHONY CLARK, individually Case No. 11 and on behalf of all others similarly 5:24−cv−01903−SSS−DTB situated,

STIPULATED

13 Plaintiff, PROTECTIVE ORDER 14 v.

FREEDOM FOREVER LLC, 17 Defendant.

24 25 26 27 28 - 1 - This Stipulated Protective Order is entered into between (1) Plaintiff, Jon Anthony Clark (“Plaintiff”); and (2) Defendant, Freedom Forever LLC (“Defendant” or “Freedom Forever”) in this case, styled Clark v. Freedom Forever LLC, Case No. 5:24-cv-01903-SSS-DTB (hereinafter, the “Action”). Plaintiff and Defendant will collectively be referred to hereinafter as the “Parties.” 6 1. INTRODUCTION 7 1.1 Purposes and Limitations. Discovery in this Lawsuit is likely to 8 involve production of confidential, proprietary, or private information for which 9 special protection from public disclosure and from use for any purpose other than 10 prosecuting this litigation may be warranted. Accordingly, the Parties hereby 11 stipulate to and petition the Court to enter the following Stipulated Protective 12…