Mohammed Elokour v. Safety Holdings, Inc. d/b/a Sambasafety

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

5 Case No. 2:25-cv-09640-JFW-SSC MOHAMMED ELOKOUR,

Plaintiff, STIPULATED PROTECTIVE v. ORDER1

SAFETY HOLDINGS, INC. d/b/a SAMBASAFETY, Defendant

13 14 1. INTRODUCTION 15 1. Purposes and Limitations. Discovery in this action is likely to involve 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 petition the court to enter the following Stipulated Protective Order. The parties 20 acknowledge that this Order does not confer blanket protections on all disclosures or 21 responses to discovery and that the protection it affords from public disclosure and 22 use extends only to the limited information or items that are entitled to confidential 23 treatment under the applicable legal principles. 24

26 1 This Stipulated Protective Order is substantially based on the model…