Wanderer

M micichhaaeel lE.b. rBewreewr@er bakermckenzie.com Baker & McKenzie LLP Two Embarcadero Center, 11th Floor San Francisco, CA 94111-3802 Telephone: +1 415 576 3000 Facsimile: +1 415 576 3099 Attorneys for Defendant

KIEWIT INFRASTRUCTURE WEST CO.

6 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA STEPHEN WANDERER, as an individual and No. 2:18-cv-02898-WBS-DB in his representative capacity, STIPULATED PROTECTIVE ORDER Plaintiff, 12 v. 13 KIEWIT INFRASTRUCTURE WEST CO.; and DOES 1 through 25, inclusive, Defendants. 16 1. PURPOSES AND LIMITATIONS 17 Disclosure and discovery activity in this action are likely to involve production of 18 confidential, proprietary, or private information for which special protection from public disclosure 19 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 20 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective 21 Order. The parties acknowledge that this Order does not confer blanket protections on all 22…