USA v. Montrose Chemical

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA

and STATE OF CALIFORNIA, Case No. 2:90-cv-03122 DOC(GJSx)

Plaintiffs, [PROPOSED] STIPULATED v. PROTECTIVE ORDER1

MONTROSE CHEMICAL CORP. OF CALIFORNIA, et al., 15 Defendants. 16 17 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 that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends 26 27 only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. B.…