Patricia Laucella v. Medtronic, Inc.

INTRODUCTION

21 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. 26 The parties acknowledge that this Order does not confer blanket protections 27 on all disclosures or responses to discovery and that the protection it affords from 1 entitled to confidential treatment under the applicable legal principles. The parties 2 further acknowledge that this Stipulated Protective Order does not entitle them to 3 file confidential information under seal; Civil Local Rule 79-5 sets forth the 4 procedures that must be followed and the standards that will be applied when a party 5 seeks permission from the court to file material under seal. Specifically, under Civil 6 Local Rule 79-5, the parties acknowledge that if any party seeks to file under seal 7 any Protected Material it must comply with Civil Local Rule 79-5. Protected 8 Material may only be filed…