Beyond Blond Productions, LLC v. Edward Heldman III

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

BEYOND BLOND PRODUCTIONS, LLC, ) Case No. 2:20-cv-05581-DSF- a California limited liability company; ) GJSx ) 13 Plaintiff, ) [PROPOSED] STIPULATED ) PROTECTIVE ORDER v. ) 15 ) EDWARD HELDMAN III, an individual; ) COMEDYMX, INC., a Nevada corporation; ) 17 COMEDYMX, LLC, a Delaware limited ) liability company; and DOES 1-10; ) ) 19 Defendants. ) ) AND RELATED CLAIMS. ) 22 ///

/// 25 /// 26 27 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 …