First Citizens Bank and Trust Company v. Taipei Investments LLC

1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 WESTERN DIVISION 13 14 FIRST CITIZENS BANK & TRUST Case No. 2:19-cv-07582-PSG-AFM COMPANY, a North Carolina Hon. Magistrate Judge Alexander F. 15 corporation, MacKinnon 16 Plaintiff, DISCOVERY MATTER 17 v. 18 [PROPOSED] STIPULATED TAIPEI INVESTMENTS LLC, a PROTECTIVE ORDER 19 California limited liability company; 20 SERGIO GARCIA-MUNGUIA, an individual; PROMATE PRODUCE 21 USA, INC., a California corporation; and 22 DOES 1-10, inclusive, 23 Defendants. 24 25

AND RELATED COUNTERCLAIMS.

26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge…