Noveon Surgery Center, Inc. v. Teamsters Western Region and Local 177 Health Care Plan
Opinion
Trial Court Opinion
Case 2:22-cv-01266-MCS-GJS Document Filed 01/24/ Page 1 of Page ID #:187
1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 NOVEON SURGERY CENTER, INC., Case No. 2:22−cv−01266−MCS−GJS a California Corporation, STIPULATED PROTECTIVE Plaintiff, ORDER1 13 v. Complaint Filed: February 24, 2022
TEAMSTERS WESTERN REGION &
LOCAL 177 HEALTHCARE PLAN; AND DOES 1 to 100, 16 Defendants. 17
19
23 // // // 25 // // 27 28 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures. Case 2:22-cv-01266-MCS-GJS Document Filed 01/24/ Page 2 of Page ID #:188
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…