Kohar Kesian v. Target Corporation

Case 2:21-cv-01787-ODW-RAO Document Filed 01/19/ Page 1 of Page ID #:403

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 KOHAR KESIAN, an individual, Case No. 2:21-cv-01787-ODW-RAO

Plaintiff, [Otis D. Wright, II, Department 5D]

v.

STIPULATED PROTECTIVE

TARGET CORPORATION, and DOES ORDER 1 through 100, Inclusive, 15 Defendants.

1. A. 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 information or items that are entitled to confidential treatment 26…