Nick Gaige, on behalf of himself and all others similarly situated v. EXER HOLDING COMPANY, LLC

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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6 NICK GAIGE, on behalf of himself Case No. 2:24-CV-06099-AH-AJR and all others similarly situated, 7 [PROPOSED] STIPULATED 8 Plaintiff, PROTECTIVE ORDER vs. 9

10 EXER HOLDING COMPANY, LLC 11 Defendant. 12

13 1. GENERAL 14 1.1 Purposes and Limitations. Discovery in this action is likely to involve 15 16 production of confidential, proprietary, or private information for which special 17 protection from public disclosure and from use for any purpose other than prosecuting 18 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 19 20 petition the Court to enter the following Stipulated Protective Order. The parties 21 acknowledge that this Order does not confer blanket protections on all disclosures or 22 responses to discovery and that the protection it affords from public disclosure and 23 24 use extends only to the limited information or items that are entitled to confidential 25 treatment under the applicable legal principles. The parties further acknowledge, as 26 set forth in Section 12.3, below, that this Stipulated…