Faramarz Naeim v. Robert L. Wilkie

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION FARAMARZ NAEIM, No. CV 2:19-CV-06126 DDP (AFMx) Plaintiff, [PROPOSED] STIPULATED

PROTECTIVE

v. ORDER1 ROBERT L. WILKIE, in his Official Capacity, Secretary, Department of Veterans Affairs; and DOES 1 through 10. 16 Defendants. 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 only to the limited information or items that are 26 …