Josh Goldman, each individually and on behalf of all others similarly situated v. DOVEL & LUNER, LLP
Opinion
trial_court Opinion
Richard Lyon (Cal. Bar No. 229288) 1 rick@dovel.com 2 Jonas Jacobson (Cal Bar No. 269912) 3 jonas@dovel.com Simon Franzini (Cal. Bar No. 287631) 4 simon@dovel.com 5 DOVEL & LUNER, LLP 201 Santa Monica Blvd., Suite 600 6 Santa Monica, California 90401 7 Telephone: (310) 656-7066 Facsimile: (310) 656-7069 8
9 Attorneys for Plaintiff 10
11
UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA 13
14 Josh Goldman, each individually and Case No. 2:25-cv-06582-DSF-AJR 15 on behalf of all others similarly situated, 16 [PROPOSED] STIPULATED 17 Plaintiff, PROTECTIVE ORDER
18 v. 19 V Shred, LLC., 20
21 Defendant. 22 23 24 25 26 27 28 1 Plaintiff Josh Goldman, LLC (“Plaintiff”), by and through its counsel of record 2 Dovel & Luner LLP, and Defendant V Shred, LLC (“Defendant”), by and through its 3 counsel of record, Procel Levine LLP, agree to adopt the Model Protective Order 4 appearing on the website of Honorable A. Joel Richlin, the terms of which are set forth 5 below. 6 1. GENERAL 7 1.1 Purposes and Limitations. Discovery in this action is likely to involve 8 production of …