Guzman

CNA COVERAGE LITIGATION GROUP

ROBERT C. CHRISTENSEN (SBN 151296)

Email: robert.christensen@cna.com 555 12th Street, Suite 600 Oakland, CA 94607 Telephone: 510.645.2306 Facsimile: 510.645.2323

Attorneys for Plaintiff

CONTINENTAL CASUALTY COMPANY

6 7 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA CONTINTENTAL CASUALTY CASE NO.: 2:19-cv-01975-KJM-CKD

COMPANY,

11 Plaintiff, STIPULATED PROTECTIVE ORDER 12 vs.

LETHESIA GUZMAN; FAAFETAI AND

RACHEL TALIAOA; L. M., a minor by and Complaint Filed: 9/27/19 through her Guardian Ad Litem THOMAS NICHOLS; D. M., and N. M., by and through their Guardian Ad Litem, Patricia Montejano,

and DOES 1-10, inclusive, Defendants. 18 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…