Sara DeRosa v. ViacomCBS, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 SARA DEROSA, Individually, and On Behalf of others similarly situated, Case No. 2:20-cv-02965-MCS (GJSx)

Plaintiff,

CLASS ACTION

v.

STIPULATED [PROPOSED]

VIACOMCBS INC.; CBS STUDIOS, PROTECTIVE ORDER1

INC.; SESSIONS PAYROLL

MANAGEMENT, INC.;

FIRSTHAND PRODUCTIONS,

INC.; EAST END PRODUCTIONS,

INC.; SNAPSHOT PRODUCTIONS,

INC.; GAIL LEVINE; GREGG

LEVINE; BOARD OF TRUSTEES

OF THE AFTRA RETIREMENT

FUND; BOARD OF TRUSTEES OF

THE SAG PRODUCERS PENSION

PLAN; BOARD OF TRUSTEES OF

THE SAG-AFTRA HEALTH PLAN; and DOES 1-50, 21 Defendants.

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 proposed terms for confidential treatment of certain…