Todd Bigelow v. Adventure Photo Tours, Inc.

Case P:21-cv-09788-SB-JPR Document Filed 04/05/ Page1of17 Page ID #:181 NOTE: CHANGES MADE BY THE COURT UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 10 A 11 |} TODD BIGELOW, Case No. 2:21-cv-09788-SB-JPR □□□ Plaintiff, PROPOSED ORDER RE 3 z STIPUEATED PROTECTIVE □□ □□ ADVENTURE PHOTO TOURS, INC., The Hon. Stanley Blumenfeld, Jr. BOO inclustve avdcach oF theme Trial Date: TBD = Defendant. Bl

PURPOSES AND LIMITATIONS

A. □ Discovery in this action is likely to involve production of confidential, 20 || proprietary, or private information for which special protection from public disclosure 21 || and from use for any purpose other than prosecuting this litigation may be warranted. 22 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 23 || following Stipulated Protective Order. The parties acknowledge that this Order does ||not confer blanket…