United States v. US GC Investment LLC

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA

ex rel. AZIZA GEORGIAN, Case No. 2:22-cv-2182 AB-PDx 10

Plaintiffs, 11

STIPULATED PROTECTIVE

v. ORDER1 12

13 US GC INVESTMENT LP et al.,

Defendants. 14

15 16 1. A. PURPOSES AND LIMITATIONS 17 Discovery in this action is likely to involve production of confidential, 18 proprietary, or private information for which special protection from public 19 disclosure and from use for any purpose other than prosecuting this litigation may be 20 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 21 the following Stipulated Protective Order. The parties acknowledge that this Order 22 does not confer blanket protections on all disclosures or responses to discovery and 23 that the protection it affords from public disclosure and use extends only to the 24 limited information or items that are entitled to confidential treatment under the 25 applicable legal principles. 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 …