First Citizens Bank and Trust Company v. Taipei Investments LLC

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 13 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. [PROPOSED] STIPULATED TAIPEI INVESTMENTS LLC, a PROTECTIVE ORDER 19 California limited liability company; SERGIO GARCIA-MUNGUIA, an individual; PROMATE PRODUCE 21 USA, INC., a California corporation; and DOES 1-10, inclusive, 23 Defendants. 24

AND RELATED COUNTERCLAIMS.

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