KC & HC, Inc. v. Dillard's, Inc.

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 KC & HC, INC., a California corporation, Case No. 2:19-cv-06691-DMG-FFM

14 Plaintiff,

PROTECTIVE ORDER PURSUANT

15 vs. TO STIPULATION 16 DILLARD'S, INC., a Delaware Corporation; GLORIA LANCE, INC., 17 individually and d/b/a “Figueroa and Flower,” a California corporation; and 18 DOES 1 through 10, 19 Defendants. 20

21

22 23 1. INTRODUCTION 24 1.1 PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary, or private information for which special protection from public 27 disclosure and from use for any purpose other than prosecuting this litigation may be 28 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 1 the following Stipulated Protective Order. The parties acknowledge that this Order 2 does not confer blanket protections on all disclosures or responses to discovery and 3 that the protection it affords from public disclosure and use extends only to the 4 limited information or items…