Michelle Mills v. Molina Healthcare, Inc.

Case 2:22-cv-01813-SB-GJS Document 117 Filed 11/29/ Page 1 of Page ID #:1713

7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 MICHELLE MILLS, et al., Case No. 2:22-cv-01813-SB-GJS Plaintiffs, [PROPOSED] STIPULATED v. PROTECTIVE ORDER1 13 MOLINA HEALTHCARE, INC., et al., Judge: Hon. Stanley Blumenfeld Jr. 14 Defendants. Magistrate: Hon. Gail J. Standish

16 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…