Tacori Enterprises v. S. Kashi and Sons

2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 TACORI ENTERPRISES, Case No. 2:18-cv-09921-R-AFM

11 Plaintiff, [PROPOSED] STIPULATED

PROTECTIVE ORDER1

12 v.

DISCOVERY MATTER

13 S. KASHI & SONS,

14 Defendant. Alexander F. MacKinnon 15

16 17 18 19 20 21 22 23 24 25 26 27

28 1 This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 2 Discovery in this action is likely to involve production of confidential, proprietary 3 or private information for which special protection from public disclosure and from use for 4 any purpose other than prosecuting this litigation may be warranted. Accordingly, the 5 parties hereby stipulate to and petition the Court to enter the following Stipulated Protective 6 Order. The parties acknowledge that this Order does not confer blanket protections on all 7 disclosures or responses to discovery and that the protection it affords from public 8 disclosure and use extends only to the limited…