Terry Fabricant v. Net Element, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA TERRY FABRICANT, individually ) Case No. 2:19-cv-02451-ODW(ASx) ) and on behalf of all others similarly ) situated, ) PROTECTIVE ORDER ) Plaintiff, ) ) ) v. ) ) PAYMENTCLUB INC., ) ) Defendants. ) ) 17 1. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary or private information for which special protection from public 20 disclosure and from use for any purpose other than pursuing this litigation may 21 be warranted. Accordingly, the parties hereby stipulate to and petition the 22 Court to enter the following Stipulated Protective Order. The parties 23 acknowledge that this Order does not confer blanket protections on all 24 disclosures or responses to discovery and that the protection it affords from 25 public disclosure and use extends only to the limited information or items that 26 are entitled to confidential treatment under…