Hunter Kerhart v. Memorial Health Services; et al.

stephen@donigerlawfirm.com Benjamin F. Tookey (SBN 330508) btookey@donigerlawfirm.com

DONIGER / BURROUGHS

603 Rose Avenue Venice, CA 90291 5 Telephone: (310) 590-1820 Attorneys for Plaintiff 7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

HUNTER KERHART,

12 Plaintiff, Case No. 2:25-cv-05188-AJR v. [PROPOSED] STIPULATED MEMORIAL HEALTH SERVICES; et PROTECTIVE ORDER al., 15 Defendant. 16 17 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 extends only to the limited…