Ivannia Lara v. American Medical Systems, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

10 11 IVANNIA LARA, Case No. 2:19-cv-09981-JAK-AFM Plaintiff,

DISCOVERY MATTER

vs. 14 AMERICAN MEDICAL SYSTEMS, AMENDED [PROPOSED]

INC.; AMERICAN MEDICAL CONFIDENTIALITY AND

15 SYSTEMS, LLC, individually and f/k/a PROTECTIVE ORDER

AMERICAN MEDICAL SYSTEMS,

16 INC.; AMERICAN MEDICAL

SYSTEMS HOLDINGS, INC.;

17 ASTORA WOMEN'S HEALTH, INC.; ASTORA WOMEN'S HEALTH LLC; 18 ASTORA WOMEN'S HEALTH

HOLDINGS, LLC; ASTORA

19 HOLDINGS, LLC; ENDO

PHARMACEUTICALS, INC.; ENDO

20 PHARMACEUTICALS HOLDINGS,

INC.; ENDO HEALTH SOLUTIONS,

21 INC.; and DOES 1-10, inclusive, Defendants. 23 24 25 26 27 WHEREAS, Plaintiff Ivannia Lara (“Plaintiff”), and Defendants American 2 Medical Systems, LLC; Astora Women’s Health, LLC; Astora Holdings LLC; Endo 3 Health Solutions, Inc.; and Endo Pharmaceuticals, Inc. (“Defendants”) (collectively, 4 “the parties”), jointly believe that entry of a protective order pursuant to Federal Rule 5 of Civil Procedure 26(c) should be applied to this matter; 6 …