Vetstem Biopharma, Inc. v. California Stem Cell Treatment Center, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

VETSTEM BIOPHARMA, INC., CASE NO. 2:19-CV-04728-AB-FFM

12 Plaintiff, JOINT STIPULATION FOR ENTRY OF STIPULATED PROTECTIVE vs. ORDER

CALIFORNIA STEM CELL

TREATMENT CENTER, INC.,

JURY TRIAL DEMANDED

Defendant.

The parties agree during the course of discovery it may be necessary to disclose certain confidential information, including protected health information (“PHI”) as defined by HIPAA, relating to the subject matter of this action. They agree certain categories of such information should be treated as confidential, protected from disclosure outside this litigation, and used only for purposes of prosecuting or defending this action and any appeals. The parties jointly request entry of a protective order to limit the disclosure, dissemination, and use of certain identified categories of confidential information. The parties assert in support of their request that protection of the identified…