Damien D. Smith v. City of Los Angeles California

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 DAMIEN D. SMITH, Case No. CV23-04739-PA-RAO

Plaintiff,

v. [PROPOSED] PROTECTIVE

CITY OF LOS ANGELES, ORDER1

CALIFORNIA, LOS ANGELES

POLICE DEPARTMENT, CHIEF OF

POLICE MICHEL R. MOORE, DOE OFFICER GUILLEN #38355, and Does 1 through 50, 17 Defendant. 18 19 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 27 discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to…