D. Gibbs Policy, LLC v. AXA Equitable Life Insurance Company
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
D. GIBBS POLICY, LLC, a Nevada
limited company, Case No. 2:20-cv-04006-DSF-RAO Plaintiff,
STIPULATED PROTECTIVE
v. ORDER1 AXA EQUITABLE LIFE INSURANCE COMPANY, a Delaware Corporation. Defendant. Complaint Filed: April 30, 2020 Trial Date: None Set 16 17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary and private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may 21 be warranted and the full extent and nature of which is not currently known to the 22 parties. Accordingly, the parties hereby stipulate to and petition the Court to enter 23 the following Stipulated Protective Order. The parties acknowledge that this Order 24 does not confer blanket protections on all disclosures or responses to discovery and 25 26 1 This Stipulated Protective Order is substantially based on the model…