Golnaz Paya, individually and on behalf of all others similarly situated v. Macy’s Inc.

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

9 Golnaz Paya, individually and on Case No. 2:24-cv-10065-JLS- 10 behalf of all others similarly situated, PDx 11 Plaintiff, STIPULATED PROTECTIVE 12 ORDER v. 13 Macy’s Inc., 14 Defendant. 15 16 1. PURPOSES AND LIMITATIONS 17 Discovery in this action is likely to involve production of confidential, 18 proprietary or private information for which special protection from public 19 disclosure and from use for any purpose other than pursuing this litigation may 20 be warranted. Accordingly, the parties hereby stipulate to and petition the 21 Court to enter the following Stipulated Protective Order. The parties 22 23 acknowledge that this Order does not confer blanket protections on all 24 disclosures or responses to discovery and that the protection it affords from 25 public disclosure and use extends only to the limited information or items that 26 are entitled to confidential treatment under the applicable legal principles. 27 28 1 2. GOOD CAUSE STATEMENT 2 This action is likely to involve trade…