Skilled Facility Health Care Solutions, Inc. v. SNF Wound Care

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

SKILLED FACILITY HEALTH CARE SOLUTIONS, INC., Case No. 2:22-cv-08517-WLH-RAO SKILLED WOUND CARE; THE

COLLEGE OF LONG TERM CARE,

[PROPOSED] STIPULATED

PROTECTIVE ORDER1

Plaintiffs, v.

SNF WOUND CARE, Defendant.

18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 23 enter the following Stipulated Protective Order. The parties acknowledge that this 24 Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 27 only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 3 B. GOOD…