Kierra Thomas v. Nissan North America, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 KIERRA THOMAS, an individual, ) CASE NO.: 8:23-cv-00164 FWS (JDEx) 11 ) Plaintiff, ) ) STIPULATED PROTECTIVE ORDER vs. ) )

NISSAN NORTH AMERICA, INC., )

a California Corporation, and DOES ) through 10, inclusive, ) ) Defendants. )

18 1. 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 pursuing 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…