Michael Russell, Joseph Preston, and James Tosches, individually, on behalf of all others similarly situated, and on behalf of the general public v. Dave Inc. and Evolve Bank & Trust

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 Michael Russell, Joseph Preston, and CASE NO. 2:25-cv-04029-MRA-MBKx 12 James Tosches, individually, on behalf of all others similarly situated, and on behalf [PROPOSED] STIPULATED 13 of the general public, PROTECTIVE ORDER 14 Plaintiffs, 15 vs. 16 Dave Inc. and Evolve Bank & Trust, 17 Defendants. 18 1. GENERAL 19 1.1 Purposes and Limitations. Discovery in this action is likely to involve 20 production of confidential, proprietary, or private information for which special 21 protection from public disclosure and from use for any purpose other than prosecuting 22 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 23 petition the Court to enter the following Stipulated Protective Order. The parties 24 acknowledge that this Order does not confer blanket protections on all disclosures or 25 responses to discovery and that the protection it affords from public disclosure and 26 use extends only to the limited information or items that are entitled to confidential…