USA v. Montrose Chemical

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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

UNITED STATES OF AMERICA

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

12 Plaintiffs, [PROPOSED] STIPULATED 13 v. PROTECTIVE ORDER1

14 MONTROSE CHEMICAL CORP. OF CALIFORNIA, et al., 15 Defendants. 16 17 18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public 21 disclosure and from use for any purpose other than prosecuting this litigation may 22 be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to 23 enter the following Stipulated Protective Order. The Parties acknowledge that this 24 Order does not confer blanket protections on all disclosures or responses to 25 discovery and that the protection it affords from public disclosure and use extends 26 27 1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 B.…