Tacori Enterprises v. S. Kashi and Sons

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA TACORI ENTERPRISES, Case No. 2:18-cv-09921-R-AFM

Plaintiff, [PROPOSED] STIPULATED

PROTECTIVE ORDER1

v.

DISCOVERY MATTER

S. KASHI & SONS,

Defendant. Alexander F. MacKinnon

16 17 18 19 20 21 22 23 24 25 26

1 This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 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…